Good morning, Gregory,
Thank you for bringing up this topic. It is an important subject to discuss and your input is greatly appreciated. The BOMA Advocacy team has been heavily involved in this, including multiple discussions with the White House. We've also engaged our federal and industry partners, including EPA, GSA, and the Real Estate Roundtable. We're working on comments, and the timing of the Winter Business Meeting couldn't be better to gather the committee's thoughts. This will be on the agenda for discussion during the ESR portion of the Legislative Committees meeting on Monday the 29th from 1pm to 4pm. As you began to highlight, this is a great topic to delve into and I expect some great conversations to take place during the meeting.
Looking forward to hearing from everyone,
Cameron
------------------------------
Cameron Macuch
Manager of Sustainability & State Policy
BOMA International
Washington DC
(202) 326-6342
------------------------------
Original Message:
Sent: 01-19-2024 08:17
From: Gregory Territo
Subject: White House Office of Domestic Climate Policy RFI for "Zero Emissions Building" Definition
Good Morning ESR Committee,
I received an email from ENERGY STAR outlining an effort by the White House Office of Domestic Climate Policy - they are in the process of developing a national definition for "zero emissions building" and are currently seeking comments, data, and other feedback on the draft definition that can be found here: National Definition of a Zero Emissions Building: Part 1 Operating Emissions -- Version 1.00, Draft Criteria (energy.gov). More information about the RFI can be accessed here: National Definition for a Zero Emissions Building | Department of Energy. I think this is a great opportunity for BOMA to contribute to the national conversation on emissions and potentially impact the government's use of our buildings. That said, the due date for input is February 5th, so there is not a lot of time to discuss and prepare feedback. They are also hosting a second virtual listening session (I received the email from ENERGY STAR 2 days ago, the first virtual session was January 11th) on Tuesday, January 30, 2024 @ 10:30 a.m. ET if anyone would like to attend. It looks like the RFI was released on January 3rd - and given the importance of this topic and the breadth of stakeholders around the country, I'm surprised that there was only 1 month allotted for feedback. I would be happy to participate in a discussion of ideas to determine what suggestions, if any, we have for revisions to the definition. After a first readthrough, I already have several thoughts, and to kick things off I'll share an initial consideration:
The first criterion laid out for "zero emissions building" is that they are "highly energy efficient" - however, energy efficiency does not necessarily relate to carbon emissions (especially as measured by ENERGY STAR - where efficiency is basically energy use/sq ft, rather than energy use per emission or per product). I would contend that there is no relevance to including energy efficiency in a "zero emissions building" definition, and this criterion could be counterproductive to efforts to reduce emissions. To demonstrate the concept, a highly efficient building that burns natural gas on site has more direct emissions than a highly inefficient building that is powered entirely by electricity. High efficiency (as commonly measured at the building level) does not mean low or zero emissions.
Let me know if anyone would like to schedule a call to have a discussion on the topic - or perhaps we may want to allot time at Winter Business Meeting to formalize a response as an organization.
Best,
Gregory Territo
President
Territo Information Systems
ECA0000650
gterrito@territo.com
407-798-0266
www.territoinfo.com
------------------------------
Gregory Territo
Territo Electric, Inc.
Ocoee FL
------------------------------