federal action on climate change

New Retrocommissioning Program Toolkit for Local Governments

As part of its efforts to help local governments comply with federal and state retrocommissioning codes and policies, the California Sustainability Alliance (Alliance) has developed a Retrocommissioning Program Toolkit specifically for municipal facility use.

Retrocommissioning (RCx) is a method of systematically examining the operation and maintenance of an existing building’s systems in order to identify ways to improve overall building performance. It offers a relatively quick and low-cost way to help building owners ensure that energy efficiency features and equipment specified in the building design are installed and operating as intended - and as required to meet occupants’ needs. 

The Alliance created its RCx Program Toolkit to help local government staff develop and implement a municipal facility retrocommissioning program.  The RCx Toolkit complements existing portfolio management tools and utility management systems, helping the user take the “next step” once a decision has been made to incorporate retrocommissioning into municipal facility standard operating procedures.  Although focused on the performance testing and documentation components, the Toolkit also provides resources, such as model commissioning specifications, to facilitate the entire commissioning process.

In addition to a detailed step-by-step description of the RCx program development processes of planning and preparation, creating data infrastructure, and collecting baseline data, the Toolkit includes necessary tools and resources to implement the program such as:

  • Sample RCx Action Plan;
  • References to common RCx resources and procedures;
  • Model Request for Proposals (RFP) language;
  • The RCx Dashboard, a spreadsheet tool that allows the user to enter basic building information to identify potential RCx candidates and track RCx program accomplishments.

The RCx Toolkit is designed to be flexible enough to be a complementary resource for an energy manager in a large local government or to be the sole RCx Program management tool for facility and public works staff in smaller jurisdictions.  It may be used to facilitate RCx for an entire portfolio of buildings, or for a defined sub-group, such as all fire stations or libraries.  Alternatively, a subset of the Toolkit’s procedures can serve to guide local government staff through retrocommissioning those measures for which that team is responsible, or to provide to its maintenance contractor. 

Depending on a government’s specific situation, the RCx Dashboard can aid in prioritizing buildings and identifying RCx candidates.  Data or analyses from other tools such as the EPA’s Portfolio Manager or a utility management system also function to prioritize the buildings, in which case, the Toolkit can work as a complementary resource library and tracking tool.  For example, for planning a heating, ventilation, and air conditioning (HVAC) system replacement, the Toolkit includes sample retrocommissioning RFP language to ensure the HVAC contractor performs functional tests and provides the required documentation to the project team.  For projects completed by internal staff, such as lighting replacements, the Toolkit’s RCx functional tests can be used to document proper installation and operation of the newly installed lighting system. 

New SEC guidelines may cause an outbreak of sustainability reporting.

The Securities and Exchange Commission (SEC) has for the first time released guidelines for public companies that define the extent of the disclosures they should make relating to the issue of climate change. This is good news for investors, who rely on comprehensive and accurate information to make their investment decisions. Institutional investors, such as pension funds, have been active in lobbying the SEC to tighten the rules about what a company needs to report when it comes to the risks and opportunities relating to climate change. Groups active in the disclosure debate include the Environmental Defense Fund and CERES. In June 2009, the Investor Network on Climate Risk petitioned the SEC to issue guidance outlining climate-related 'material risks' - such as new regulations, physical impacts, new economic and business opportunities and other climate-related trends - that companies should be disclosing to investors. According to the SEC's news release, the interpretative guidance highlights four areas as examples of where climate change may trigger disclosure requirements:

  • Impact of Legislation and Regulation: When assessing potential disclosure obligations, a company should consider whether the impact of certain existing laws and regulations regarding climate change is material. In certain circumstances, a company should also evaluate the potential impact of pending legislation and regulation related to this topic.
  • Impact of International Accords: A company should consider, and disclose when material, the risks or effects on its business of international accords and treaties relating to climate change.
  • Indirect Consequences of Regulation or Business Trends: Legal, technological, political and scientific developments regarding climate change may create new opportunities or risks for companies. For instance, a company may face decreased demand for goods that produce significant greenhouse gas emissions or increased demand for goods that result in lower emissions than competing products. As such, a company should consider, for disclosure purposes, the actual or potential indirect consequences it may face due to climate change related regulatory or business trends.
  • Physical Impacts of Climate Change: Companies should also evaluate for disclosure purposes the actual and potential material impacts of environmental matters on their business.

As the New York Times reports, the new guidelines were welcomed by pension funds and other large institutional money managers:

“We’re glad the S.E.C. is stepping up to the plate to protect investors,” said Anne Stausboll, chief executive of the California Public Employees Retirement System, the nation’s largest public pension fund and one of the parties that petitioned for the guidance. “Ensuring that investors are getting timely, material information on climate-related impacts, including regulatory and physical impacts, is absolutely essential. Investors have a fundamental right to know which companies are well positioned for the future and which are not.”

In the commercial real estate world, the SEC ruling may provide the impetus for public real estate companies to take seriously the measurement and reporting of energy efficiency and other measures of the sustainability of their real estate holdings. Pension funds are likely to lead the way in pushing for such disclosures from real estate companies with which they undertake joint ventures, as well as from the REITs whose shares they own. Is it only a matter of time before the issuance of a “Sustainability Report” is as commonplace for real estate companies as the annual financial report is today?

An Eventful Week for Climate Change in the U.S.

This has been a busy week for climate change activity in the U.S. Here are three stories that struck me as particularly interesting:

Debate Commences on Senate Climate Legislation. The Kerry Boxer bill enters the ring, weighing in at over 800 pages (much of taken from the earlier Waxman Markey bill that passed the House in June), this is the bill that will define America’s response to climate change. Climate policy advocates swarmed the bill as soon as it was released and positions and alliances were already starting to form this week. The emission reduction target has been increased from 17% to 20% below 2005 levels by 2020, the provision for the use of international offsets has been cut back, and a ceiling on carbon price has been proposed. Interestingly, there appears to be relatively strong support in the business community for this bill, but there will be a difficult path to passage. The world community convenes in Copenhagen in December to address the increasingly worrisome warnings that dangerous climate change is closer than had been hoped. Virtually nobody expects the bill to pass before the Copenhagen meeting, but the tenor of the US debate between now and then will go a long way to determining the outcome. Watch for more on this story, much more, in the weeks ahead.

Coming to a Post Office Near You! Perhaps realizing that in the absence of a climate law the administration will have to demonstrate its commitment to greenhouse gas reduction in other ways, President Obama issued an Executive Order this week calling for a 20% reduction in GHG emissions from government operations, and federal agencies have just 90 days to show how they will do it. This is a sleeper. The federal government owns 500,000 buildings and is a significant purchaser of just about everything that uses energy. If the government delivers on these targets it will cause a significant shot in the arm to the US efficiency, renewable energy and recycling industries, and it will have wide ranging repercussions for supply chains everywhere.

PG&E Quits U.S. Chamber of Commerce in protest over its position on climate change. The PG&E blog entry announcing the move, entitled “Irreconcilable Differences”, makes for interesting reading. This is a sign of the times if there ever was one. Those of you who were around in the early days of the climate change policy debate will remember how rare it was to find any business support for action on global warming. That has changed in the last few years as the inevitability of an energy transformation has become apparent, and as astute members of the business community begin to appreciate the upside to climate change policy. American business is waking up to the enormity of the clean energy opportunity, and not a moment too soon.