Building Optimization: Roles & Responsibilities
What you need to know about the new Clean Building Performance Standard (CPBS).
Washington State now requires that building owners have a formal, documented approach to managing their buildings for energy efficiency. They’ve adopted ASHRAE Standard 100: Energy Efficiency in Existing Buildings —with amendments. This is referred to as the Clean Building Performance Standard (CPBS).
Almost all buildings over 20,000 square feet of conditioned space are required to comply with these three activities:
Benchmarking to measure and track building energy performance against a target.
Developing and maintaining a program to support continuous improvement including supporting documents (referred to in the Standard as an Energy Management Plan and O&M Program).
Taking actions to maintain and improve building performance over time, including robust O&M tasking, operator/manager training and education, occupant education and engagement, asset management and improvement, and a review of energy impacts of any space and equipment changes.
In addition, larger, non-residential buildings (a/k/a Tier 1, 50,000 SF+ buildings) are required to either meet or exceed their targets or have an audit and plan to do so by their compliance date.
Clean, energy efficient buildings require a team approach. Many of the roles can be filled by the same person, and several of the roles are not specific to the Standard (e.g. owner, manager, operator).
Roles unique to the Standard were recently amended during the Tier 2 rulemaking and this affects qualifications for some roles: Energy Manager (EM), Qualified Person (QP), and (new!) Qualified Energy Manager (QEM). The Energy Manager responsibilities are the same, but the QEM takes the place of the QP for reporting quality assurance.
Energy Manager (EM)
Responsibilities:
Minimize the energy use of the building without compromising indoor environmental quality (IEQ), including air quality, thermal comfort, visual acuity and comfort, acoustic quality.
Develop and maintain the annual Energy Management Plan and O&M program documentation.
Qualifications: There are no specific qualifications for the Energy Manager and the role may be filled by a team member with other responsibilities, including a tenant in the building.
Qualified Person (QP)
Responsibilities: Quality assurance provider for Tier 1 buildings signs off on EUI target calculation and reporting.
Qualifications: Can be filled by a team member with other responsibilities. Training and expertise in the energy management area, and three years professional experience in building energy-use analysis and one of several credentials. Options include:
A licensed professional architect or engineer in the State of Washington
A person with Building Operator Certification (BOC) Level II by the Northwest Energy Efficiency Council (NEEC)
A Certified Commissioning Professional (CCP) certified by an ANSI/ISO/IEC 17024:2012 accredited organization
A qualified energy auditor (which requires a BEAP or CEA credential)
A Certified Energy Manager (CEM) in current standing, certified by the Association of Energy Engineers (AEE)
An Energy Management Professional (EMP) certified by the Energy Management Association (EMA)
And new in Tier 2 rulemaking…
Qualified Energy Manager (QEM)
Responsibilities: Hybrid of the Energy Manager and Qualified Person specifically for Tier 2 buildings (<20,000 SF and all multifamily)
Qualifications: Three years of experience, including educational and/or professional experience, with commercial building operations and/or building energy management in addition to successful completion of clean buildings Tier 2 training program as specified by the Department of Commerce.
Existing Roles and Responsibilities for Compliance
The remaining key roles are straightforward – the owner, property/building manager, and building operator. What is less straightforward, and will vary from building to building, is how these individuals coordinate amongst themselves, as well as with tenants, and owner’s and tenants’ service providers to address all the responsibilities and comply with the Standard.
Overall compliance is the responsibility of the owner. The only tasks that the owner cannot delegate are signing the annual energy management plan update and ensuring that all the other responsibilities are clearly delegated to other team members and followed through.
The owner can serve as the building manager, operator, and energy manager, and with the right credentials, the QP (or QEM for Tier 2). The entire compliance process can be handled in-house, with the owner staff filling all the roles.
In many cases, the coordination of responsibilities will fall to the owner’s agent, and the property management team will need to coordinate with internal and external operations and maintenance staff, tenants, and their operational staff, and an in-house or contracted EM/QP/QEM.
Critical compliance tasks are described below and can be completed by anyone–but must be then validated by a QP (Tier 1) or a QEM (Tier 2) for submission to Commerce.
Critical Task 1. Calculate the energy target and current energy use intensity.
Who? EM/QP/QEM
Calculating the EUIt (energy use target), including determining if the building has one based on the property use and meter set-up, is the specific responsibility of the Qualified Person. Others can perform the calculation using CBPS 019- EUIt Calculator Tool (found here https://www.commerce.wa.gov/growing-the-economy/energy/buildings-archive-page/clean-buildings-performance-standard-document-library/), but it is a good idea to have a QP on board to validate that early in the process.
ENERGY STAR Portfolio Manager will calculate the building’s weather normalized EUI (Energy Use intensity) – but it is useful to have the QP confirm this is set up correctly including all meters and energy use, including how onsite PV is handled.
The Energy Manager is responsible for comparing the actual performance to the target to determine compliance, or the need for an audit or other actions to improve energy performance, the need for compliance through investment criteria, or the conditional compliance path.
Critical Task 2. Develop the Energy Management Plan and O&M program.
Who? EM/QEM
Developing this program documentation (described further here) is specifically the task for the Energy Manager, though as noted, any team member can fill this role. The Qualified person (or QEM for Tier 2) will need to sign off that this document meets the requirements of the CBPS. The building or property manager is the person responsible for complying with the program documents.
These living documents may be quite involved, and the Energy Manager will need input from the property management and building operator and service providers to gather all the documentation. This ‘document’ may in practice be a collection of documents and files – with the core EMP providing a summary and framework for annual distribution to stakeholders.
Critical Task 3. Meet or exceed the EUI target (Tier 1 only)
Who? Owner/Asset Manager, Building Operator, Property Manager, EM/QEM
The third critical task is a team effort – getting the building’s energy use at or below the EUI target.
Some teams may find that their building is already meeting the EUIt and they ‘only’ need to comply with the new program management and documentation requirements of the Standard.
Others will need to improve the efficiency of their operations and potentially pursue conditional compliance. A third group, buildings without a target, will need to pursue the investment criteria path. Improving efficiency overall does not necessarily require an official audit. Known issues and building tune-ups focusing on operational factors may be enough to meet the target in time for compliance reporting.
If operational improvements and known opportunities for upgrades don’t result in meeting the target, a project will need to get a Level II ASHRAE energy audit by a qualified auditor. This is one of three roles defined in the CBPS. In addition to the Qualified Person, Qualified Auditor, the third role is Commissioning Agent. If the investment or conditional compliance path is taken, these roles will all need to be filled by qualified people. In some cases, the qualifications overlap i.e. certified auditors and commissioning agents meet the qualification for Qualified Person.
Assembling your team and coordinating roles and responsibilities is one of the first steps to take along with benchmarking your building (calculating the current EUI and EUIt).
Disclaimer: This article is for informational purposes and is not intended to replace the Standard or guidance provided by the WA Department of Commerce.
The ArchEcology team is pleased to provide services to support compliance with the WA Clean Building Performance Standard (CBPS), City of Seattle Benchmarking, Building Tune-ups, and newly approved Building Emissions Performance Standard.