The Institute for Market Transformation is the foremost authority in the United States with regard to ratings and disclosure policy, and its report Building Energy Transparency: A framework
for Implementing U.S. Commercial Energy Rating & Disclosure Policy109 is a comprehensive resource
for understanding market needs and keys to success. This report, which focuses more on energy use ratings than asset ratings, informed many of the options and recommendations listed
below.
A Comprehensive and Collaborative Approach to Implementation
The mayor of San Francisco’s cross‐functional taskforce on existing buildings played a role in shaping the San Francisco Ordinance.– Lessons learned from this task force approach could be useful in developing statewide rating systems and disclosure policies. Whether through a task force or other means, it could be beneficial to contact building owners directly and leverage and
109 Available at http://www.buildingrating.org/sites/default/files/documents/IMT‐
educate local businesses to develop programs and to support outreach. Identifying industry partners such as the Building Owners and Managers Association (BOMA), the Commercial Real
Estate Development Association (NAIOP), and the California Business Properties Association
(CBPA) can have a major effect on market acceptance of statewide energy efficiency policies. Statewide collaborative efforts can underpin a comprehensive outreach program and a media campaign to educate building owners and promote energy efficiency.
Robust Rating Systems That Are Trusted by the Market
To demonstrate the robustness of rating systems to the nonresidential buildings market, a series of case studies could form part of an outreach campaign. Case studies could highlight examples where owners took their buildings from a low to a high rating through a sequence of upgrades, for example. Collaborating and co‐branding with industry organizations (for example, BOMA, NAIOP, and CBPA) would enhance the credibility of such case studies.
Quality-Assured Rating Processes
Quality assurance and quality control are obtained through a combination of strategies. The rating process should be transparent and well‐documented. Where possible, rating systems should minimize or preferably avoid any subjective inputs (in other words, dependent on the experience and judgment of the rater). Beyond that, several options exist that can contribute to high quality rating programs:
• Training programs for raters: A consistent level of teaching is recommended for raters, and perhaps a central “train the trainer” program. Such programs should be aligned with estimates of market demand to ensure a pool of raters that will meet market and
programmatic needs.
• Rater certification: Similar to the HERS whole‐house rating system, a certification program can reinforce the value of training for raters and provide confidence among building owners in the qualification of raters and expected quality level. Certification also provides for a worst case scenario whereby certification can be revoked if raters do not meet the required standards in practice.
• Independent verification of ratings: Third‐party verification of ratings is a form of quality control that can provide further confidence in ratings for owners and policy makers. The additional cost should be considered carefully against the potential benefits. It is preferable to build quality into the process (QA) before incurring the additional cost of quality control measures.
Additional suggestions that may enhance quality assurance include requiring signatures on rating certificates and, if ratings are to be published, publishing the input values. (This would discourage entering false data inputs that inappropriately enhance a building’s rating.)
Maximize Benefits of Rating Systems
In addition to receiving a rating, market “pull” could be enhanced by adding features or integrating the rating with other programs. Establishing data exchange protocols to promote data sharing between application tools (between a rating tool and a redesign tool, or between an assessment tool and a rating tool, for example) can reduce costs and improve data integrity.
Integrating rating systems and redesign processes into energy upgrade programs can facilitate the identification of retrofit packages that are optimized for the subject building. Designing rating systems to include an application programming interface (aka “API”) can enable the market to deliver innovative benchmarking, performance monitoring, EIS, and other tools that include the ability to calculate performance ratings.
Reinforce the Connection Between Higher Ratings and Higher Property Value
A number of recent reports have documented a link between higher ENERGY STAR scores and higher property values. Initially these reports were academic in nature, but more recently there have been reports released that were cosponsored by major property owners and managers. More research is needed, especially considering a broader spectrum of property types beyond Class A offices, as well as outreach programs to develop a common and consistent
understanding of this link. Integrating rating into the property appraisal process would further reinforce the connection between ratings and property value and could lead to ratings
becoming a standard data point on a property listing. (AB 1103 may be a catalyst for this.) This in turn could lead to existing real estate databases, such as CoStar, incorporating performance ratings, resulting in correlations between rating level and property value that are determined from a much richer set of empirical data.
Phased Approach to Rating System Introduction and Disclosure
With any new rating system or disclosure legislation, a phased approach can ease market adoption. Implementation phases should consider, at a minimum, the following areas:
• Cost: Starting with voluntary programs, rebates may be offered to cover the cost of ratings. As market transformation takes place, these rebates can be reduced.
• Building size/type: A phased approach is being employed by many regulators, starting with larger buildings (which are fewer in number but encompass a high proportion of floor space), and moving to smaller buildings over time. It is also common to require public disclosure for public buildings before moving to commercial properties, to demonstrate leadership and to establish administrative processes. There is no prior example of phasing disclosure legislation based on market sectors (for example, office, hotel, grocery store).
Establish a Central Tracking Database for Ratings
The goal of AB 758 is to improve energy efficiency in California, and in doing so to create high‐ quality jobs in the state. Data inputs for ratings, as well as the ratings themselves, are critical for tracking the success of AB 758 and for tailoring specific program approaches. Web‐based rating tools can make centralized data warehousing easier and create a picture of nonresidential building energy performance in California that is larger and that has a greater depth of detail than anything in existence. A deeper understanding of the equipment and performance of California’s building stock can help target utility programs toward the systems most in need of upgrade, on a regional level, and in parallel track the performance improvements of the
building stock. DOE has established the Standard Energy Efficiency Data (SEED) Platform for states and cities to use in each of their rating disclosure programs. SEED is in beta testing by
select cities and states and shows promise to significantly reduce the costs of implementing rating disclosure programs.