Recently Senator Whitehouse (D-RI) and Congressman Waxman (D-CA-33) on behalf of the Bicameral Taskforce on Climate Change, solicited AIA's opionion on the best ways to reduce emissions through federal agency and legislative action. Please see our response below and fee free to contact me
christinafinkenhofer@aia.org with any questions or concerns!
February 20, 2013
Hon. Sheldon Whitehouse
U.S. Senate
717 Hart Senate Office Building
Washington, DC 20510
Hon. Henry Waxman
U.S. House of Representatives
2204 Rayburn House Office Building
Washington, DC 20510
Dear Senator Whitehouse and Congressman Waxman:
On behalf of the more than 80,000 members of the American Institute of Architects, thank you for the opportunity to provide comments to the Bicameral Task Force on Climate Change.
AIA members are committed to enhancing energy efficiency and improving the sustainability of the built environment. To support these goals, in 2005 the AIA adopted a position stating that all new buildings and major renovations to existing buildings be designed to meet an immediate 60-percent reduction in fossil fuel-generated energy (compared to a 2003 baseline) and that at five year intervals, that reduction target be increased by at least 10 percent until new and renovated buildings achieve carbon neutrality in 2030.
Architects across the country have embraced this principle and are currently utilizing practices that integrate built and natural systems that enhance both the design quality and environmental performance of the built environment. To further this aim, the AIA supports the development and adoption of the International Green Construction Code (IgCC), which provides model code language for states and municipalities to establish baseline sustainable design requirements for new and existing buildings including energy and water use efficiency; materials and resource use; indoor environmental quality; building impacts on the environment; site design; and sustainable building owner/facility management education. These steps not only save energy and protect the environment; they also create jobs for millions of workers in the design and construction industry.
In the past, the AIA has worked with Congress to address energy use in federal buildings. The 2007 Energy Independence and Security Act (P.L. 110-140) included a provision, spearheaded by Congressman Waxman, requiring that all new and significantly renovated federal buildings meet energy-use requirements. These targets demonstrate to the private sector that the federal government is leading by example. They help spur the development of new materials, construction techniques, and technologies to make buildings more energy efficient. And they are helping to show that significant energy reductions are both practical and cost-effective.
However, it is clear that more can and should be done to reduce the energy footprint of the built environment. To that end, the AIA would like to offer the following observations to the Task Force.
- Actions and policies federal agencies can adopt to reduce emissions
The AIA has long advocated for policies that would help federal agencies lead the market in reducing emissions. If the federal government does not demonstrate that these goals are achievable and practical, it cannot expect the private sector to follow. That is why the AIA has proposed several common-sense policies to help the federal government set an example to the industry and beyond.
CBECS. First, the Department of Energy (DOE) must update the Commercial Buildings Energy Consumption Study (CBECS). This important survey serves as the benchmark for many emission reducing provisions, but has not been updated since 2003. Although the country has a long way to go in terms of commercial building energy consumption, we have come a long way over the past ten years. We need an updated survey that will show the industry where we are in terms of energy use, and how far we have left to go.
Public/Private Coordination. The AIA commends the work the DOE has done towards collaborating with the industry in developing policies that encourage the exchange of data among private and public entities, the disclosure of energy use by the private sector, the development of robust energy modeling software, and the refinement of the business case for energy efficiency. We hope this private/public collaboration continues to grow and serves as an example to other agencies, the administration, and Congress of how the exchange and consolidation of information can lead to effective policies and practices that address energy use in the built environment.
179D Allocation Policies. Lastly, agencies must adopt a sensible and simple 179D energy efficient commercial building tax deduction allocation policy. This deduction provides up to $1.80 per square foot for energy efficient design that can be allocated to the designer in the case of a local, state, or federal building owner. Not only does this allocation provide an incentive to the designer to hit energy targets that save hundreds of thousands of dollars to taxpayers, it also provides an economic boost to the design and construction industry so that the industry can continue to provide millions of jobs nationwide. However, different federal agencies have different policies for allocating the deduction, creating confusion and inconsistency to design professionals, which ultimately hampers the effectiveness of the deduction.
- Actions/policies federal agencies can adopt to make nation more resilient to the effects of climate change.
As the federal government works to address the causes of climate change, it must take steps to strengthen the communities most vulnerable to its effects.
Training of Design Professionals. The AIA has a demonstrated record of going into communities immediately after catastrophic natural events and helping them rebuild. In order to do this, we train architects and other design professionals so that they can immediately assess damage to structures and help communities rebuild resiliently. However the scope of the problem requires a far greater investment in training personnel. With a very small allocation of funds, the federal government can undertake this training in the most vulnerable communities so that this army of highly skilled professionals becomes even more robust, when a catastrophe strikes.
Community Design Centers. This disaster planning should be made available to all communities nationwide, not just those that can afford to train their workforce. That is why the AIA has long advocated for the allocation of funding to community design centers (CDCs). These non-profit design centers go into underserved neighborhoods and towns and assess the communities' design needs. For example, if a community is prone to floods or wildfires, these centers work with the local leaders to design buildings that are critical to the community's basic vertical infrastructure. These critical needs can include community centers that serve as shelters, or low income housing that incorporate fire resistant materials. But without these community design centers, these needs often go overlooked.
- Recommended legislation
While there is a tremendous amount of work left to do in reducing energy consumption in buildings, there are steps Congress can take right now to reinforce the work the private sector is undertaking every day.
179D Extension and Enhancement. The Energy Efficient Commercial Building Tax Deduction (179D) has shown significant promise in helping both public and private sector owners reduce building energy use. Because the targets for compliance are fairly aggressive, 179D provides an incentive for owners to reach higher levels of energy savings. However, this deduction expires at the end of 2013. Congress needs to act this year to extend it and make adjustments to make it work more effectively.
Federal Buildings. Although new legislation that encourages energy efficiency is necessary, we must also protect existing laws that require energy reduction targets today. There are efforts in the Senate to undermine EISA Sec. 433, which requires new and renovated federal buildings to hit energy reduction targets leading up to net zero energy consumption in the year 2030. The AIA opposes any effort to weaken this requirement. If the federal government does not demonstrate that these goals are achievable and practical, the private sector will not go the extra step to hit these targets. By enforcing these requirements, the federal government can spur the development of new technology that will allow the industry to regularly hit these targets.
Livable, Resilient Communities. Traffic congestion is a major contributor to greenhouse gas emissions. Across the country, communities are working to create more livable, walkable downtowns and main streets that reduce congestion and improve overall health. In addition, communities also are struggling to prepare for devastating natural hazards like last fall's Superstorm Sandy. Congress can help communities by passing legislation like the Livable Communities Act (S. 1621/H.R. 3325 in the previous Congress), which provides support for communities seeking to plan in more sustainable ways; and the Safe Building Code Incentive Act (S. 3694/H.R. 2069 in the last Congress), which would provide states that enforce statewide model building codes with additional post-disaster relief assistance.
Tax Reform. Finally, as Congress deliberates tax reform, Congress has the opportunity to craft a code that promotes sustainable, livable design. It would be a grave mistake to simply wipe away all of the expenditures that incentivize energy efficiency without replacing them with smart, forward-focused proposals that seek to reduce energy consumption in the United States. Specifically, proposals that provide tax exempt bonds for transit-oriented, livable development, similar to those proposals most recently offered by the Administration, are models for what the tax code should look like in the future. In addition, traditional depreciation schedules can be amended and streamlined to encourage investments in energy efficient building components. These are simple ways to improve the code for businesses across the nation while also making an investment in the nation's future.
In conclusion, the AIA thanks you for giving us the opportunity to provide our perspectives on these important issues. We look forward to working with you and all members of Congress to advance policies that make the built environment more sustainable, resilient and vibrant.
Sincerely,
Mickey Jacob, FAIA
President
The American Institute of Architects
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Christina Finkenhofer
The American Institute of Architects
Washington DC
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