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Chicago ranks as the the #1 sustainable design city in the nation. Wake up NYC
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Chicago ranks as the the #1 sustainable design city in the nation. Wake up NYC
Chicago ranks as the the #1 sustainable design city in the nation. Wake up NYC
Presidential candidates Obama and McCain differ on how to break the nation's addition to oil while combating climate change. Read on
When Congress gets down to business on climate change, the experience of twenty-seven states could lead the way. Look ahead
With California and Texas cities at the opposite ends of the sustainability spectrum, northeast cities like Boston fall midway, with more differences between the center city and the suburbs. What are the policy implications? ABC's here
The installation of solar power plants on federal land is halted pending environmental reviews. Freeze
2008 will be a landmark year in American politics, but not for federal climate legislation. The springtime follies in the Senate will mean we must wait until next year, or perhaps longer, for any comprehensive national law. Until then, cities will remain the leaders and the laboratories in fighting climate change.
So, where do we stand today? Along with the deeply divisive conflicts within the political establishment and among industries and interest groups over national climate legislation, self-described "libertarian paternalist" behavioral economists like Thaler and Sunstein (the latter also a self-described "informal occasional advisor" to Barack Obama)i maintain that inertia, overconfidence and loss aversion, make change, whether personal or political, hard to do. From this vantage point, ambitious action on climate change, or indeed almost any action at all in Washington, could remain beyond our immediate grasp, regardless of who wins the Presidential race. In light of such prospects, Thaler and Sunstein recommend policies that can "nudge" us in the right direction.ii At the same moment, climate scientists are sounding the alarm about how fast the world is warming and the oceans are rising. They tell us that we cannot wait — and that's where thoughtful and thought — through climate policy action at an urban level could be the nudge we need now.
Out of this ferment progress will emerge - and some errors too - while we learn how to cut our carbon footprint, to measure our successes and calculate the costs. By acting methodically and starting now, cities, scholars and professionals could amass real time, real world numbers on both the cost of energy and the cost of using less of it. In turn, this information could be deployed as a front line tool in the national climate policy arena. In this precise way, urban initiatives could silence the paralyzing mantra of climate protection versus economic growth and the savage attacks of politicians like Oklahoma Senator James Inhofe who protest that climate legislation is a "tax on the poor", and the biggest government burden since FDR's New Deal.iii
Today, plaNYC 2030 is more than one year old and several of its key climate components are taking their first steps.iv The Mayor has pledged to shrink the city government carbon footprint 30% by the year 2017 and the Office of Long Term Planning and Sustainability is looking into how to get there; it's more than changing light bulbs. Consider the Energy Efficiency Program, a product of plaNYC development. The City estimates that by improving the energy efficiency of its own buildings its CO2 emissions could be cut by 50-60%. In December 2007, the administration announced several short terms actions and promised to issue a long-term plan by the end of June 2008. It has pledged to conduct base-line energy audits of ten municipal buildings as a pilot for a larger audit program. Audit findings could be invaluable both for the efforts of municipal government as well as the advancement of LEED standards for existing buildings and other high performance building projects outside the LEED protocol. That's the kind of potential impact Mayor Bloomberg calls "leading by example". In September 2008, expect an update on the City's 2007 carbon footprint report. And not to be overlooked, if the City issues an in-depth annual report this fall about Local Law 86, its two-year old green building statute, we'd have an opportunity to learn from the laws on the books.
Don't expect all the findings to be upbeat either in terms of performance or cost. There remains much to be learned about high-performance building design, construction and operations. A 2008 New Buildings Institute report found a disturbingly wide range of energy performance for new LEED-rated projects around the US. While on average, LEED buildings are 25-30% more energy efficient than non-LEED construction, of the 121 buildings in the study, 30% performed better than expected, 25% performed worse than expected, and a few had serious energy consumption problems.
What to make of this? As the Sallan Snapshot "Sustainability In Commercial Buildings-Bridging The Gap From Design To Operations" argued,
As more actual energy performance data on high-performing buildings becomes available, clearer and more realistic expectations will help to establish confidence within the building design and construction industry about costs and savings. Especially because energy cost savings are often cited as offsetting additional first costs of green buildings, it is important to narrow the gap between the predicted energy benefits and actual measured, savings. Accurate reporting of the actual performance of green buildings is important will help the industry to calibrate its expectations and move towards more consistent results and confidence in projections. Sharing operating results and lessons learned earlier rather than later can avoid repeating potential mistakes as the green buildings movement proceeds.
plaNYC 2030, of course, is more than a directive to our building stock. Trees have been planted, schoolyards are open for play after 3 pm and congestion pricing has gone down to defeat. But these developments cannot predict the degree to which the Plan will succeed because, as Tom Angotti writes, "The real test is whether the ambitious goals of creating a greener and healthier New York will be achieved. That just defies quick fixes and short-term solutions. Essential to Angotti's long-term vision is ramping up grass roots citizen involvement in the elaboration and execution of plaNYC 2030. He urges the City's fifty-nine community boards to host meetings to capture and focus citizen attention and bottom up ideas. At a recent Sallan-sponsored panel on how to shrink New York's carbon footprint, an audience member from Manhattan's Community Board 7 proposed that City government organize a climate competition, with the winning community board achieving the best cuts to its carbon footprint. What a clever idea for capturing bottom up ideas! In addition, as others have argued, plaNYC 2030 and the City's overall economic growth would benefit from adding focus and resources on education and job training for all the work that's entailed in making New York a sustainable city.
plaNYC 2030 is a work in progress and we should expect obstacles, disagreements and some stumbles as it matures. That’s standard operating procedure, not an occasion for despair. Shortly, we will post a Sallan Foundation-sponsored research report by the CUNY Building Performance Lab, Decoding the Code. It will tackle this question: how can the 2007 City Building Code help meet plaNYC 2030 carbon/energy reduction goals.
i John Cassidy, "Economics: Which Way for Obama?", New York Review of Books, June 12 2008
ii Richard Thaler and Cass Sunstein, Nudge: Improving Decisions About Health, Wealth, and Happiness, Yale University Press, New Haven, 2008
iii James Inhofe, "We Don't Need a Climate Tax on the Poor", Wall Street Journal June 3, 2008
ivFor a full summary of its first year's efforts, see plaNYC Progress Report 2008
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The big USGBC news last week was that as of January 2009 it will concentrate on standard-setting and its sister organization, the Green Building Certification Institute (GBCI), will no longer certify buildings. Instead, GBCI will become de facto an accreditation institution. Since the beginning of 2008, GBCI has administered the LEED Accredited Professional program. To conform to international standards, GBCI should become the Green Building Accreditation Institute (GBAI) and it should be moved up to a status coequal with USGBC - comparable with the Forest Stewardship Council and its sister Accreditation Services International, which started up in 2006.
The LEED standards themselves are eagerly promoted by builders seeking to improve their brands. They are also workable, because they (1) use an easy-to-follow point system, (2) have an easy-to-achieve first level, (3) are flexible, (4) offer challenges for industry leaders, (5) give incentives to builders to use green products, (6) are scalable and expandable, (7) recognize independent third-party certifications, (8) and are broad-based and transparent.
The cost for LEED is also reasonable an estimated 2 percent cost premium for silver LEED certification, 4-6 percent for gold and more for platinum (very hard to achieve). If the estimate is accurate that half the cost of LEED certification is USGBC's fee, this is very high compared with other certification programs, where the bulk of the cost is for meeting higher standards. The certification cost should drop by the end of 2009 as more certifiers are accredited. Some of the backlog should also start to get cleared up.
But, as I will show, USGBC's use of the terms "accreditation" and "certification" is mixed up in USGBC announcements. This does not inspire confidence either in USGBC's understanding of the process or in its current compliance with the related international standards. So just two cheers.
New York City Lots of Claims, Few Certificates
The basic problem with the Leadership in Energy and Environmental Design (LEED) program in New York City has been that so many are named but few are certified, making for a long queue. In December 2007, I prepared a Snapshot for the Sallan Foundation on the LEED system, later published on Huffington Post, that was mostly positive.
I congratulated LEED on the growth of its certifications nationally, as of the end of 2007, to 1,129. I noted how much consumers and builders are scrambling to meet LEED standards and LEED's impressive revenue (about $11 million) for USGBC ($40 million revenue in 2007). Also, I praised the USGBC committees that set the LEED standards because they do the job and are continuing to refine the ratings. Although not as stringent as the Architecture 2030 standards, which seek a 50 percent energy saving, the LEED standards can achieve half of that savings or more and, most important, they are easy to understand and presently dominate the marketplace.
The City of New York in 2006 recognized LEED standards by requiring adherence to them for most NYC buildings that cost at least $2 million or more to build or renovate, or for privately owned buildings that get $10 million or more of NYC subsidy. The Mayor's Office of Environmental Coordination did this by adding a new chapter 10 to Title 43 of the Rules of the City of New York.
My main concern about LEED in New York City is the big gap between claims and reality. Billboards give new buildings a boost to their brand by claiming "pursuing LEED gold", but very few certifications have actually been issued, just 15 at the end of 2007 according to the USGBC NYC Chapter website (click on FAQs):
How Long the Pursuit? The Wannabe LEED Gold CRBE Macklowe Building at 510 Madison last week.
The first certification was in 2004, for the Solaire at 20 River Terrace. The Battery Park City Authority had its own green building standards and the Solaire was planned green from the beginning, with all-EnergyStar appliances, wood certified to FSC standards and solar panels that generate 5 percent of its energy. It was therefore a cinch for the Solaire to get certified to LEED Gold in April 2004.
- One in 2005.
- Eight in 2006.
Six more in 2007 (this list adds up to 16, although the USGBC Chapter website shows 15).
Pursuing LEED Platinum. The Visionaire.
By the end of 2007, 294 NYC buildings were registered with LEED, a ratio of certificates to registrations of one in 20. Clearly, the certification process has not been keeping pace.
UK 100,000 Buildings Certified and Half a Million Being Processed
The green-buildings backlog in New York City may be contrasted with the situation in the UK, where 100,000 buildings have been certified to the Building Research Establishment Environmental Assessment Method ( BREEAM) and more than half a million more are in the registration pipeline. BREEAM won the "Best Program" Award at the 2005 Tokyo World Sustainable Building Conference for having "the most successfully executed program for promoting sustainable practices, and influencing other initiatives, worldwide."
BREEAM from the beginning opened up certification to licensed assessors, which means they are competing for business and their numbers can expand and contract along with demand. The assessors work within a rigorous quality assurance framework. BRE examines organizations that are trained to do the assessments and licenses the ones that are qualified. BREEAM coverage includes courts, EcoHomes, industrial, international, multi-residential, offices, prisons, retail and schools. Headquartered in Watford, BRE is continuing to expand its network of licensed assessors.
The Big News from USGBC
The big USGBC news last week was that as of January 2009 it will concentrate on standard-setting and its sister organization, the Green Building Certification Institute (GBCI), will no longer certify buildings. Instead, GBCI will become de facto an accreditation institution. Since the beginning of 2008, GBCI has administered the LEED Accredited Professional program. To conform to international standards, GBCI should become the Green Building Accreditation Institute (GBAI) and it should be moved up to a status coequal with USGBC comparable with the Forest Stewardship Council and its new Accreditation Services International.
GBCI is effectively becoming an Accreditation Agency in 2009.
The problem with USGBC's announcement and chart is that the terms "certification" and "accreditation" are mixed up, leading to a question about its full understanding of the difference between them. On its website, USGBC describes itself as a "third-party" certification body but USGBC is only ANSI-accredited as, and is best described as, a standard-setting body. It was never itself a properly accredited third-party certification body.
International standards are evolving and it is forgivable that USGBC should lag behind this evolution. The ISO/IEC 17011:2004 standard for agencies that accredit conformance assessment bodies, aka certification bodies or certifiers, tightens up the previous ISO Guide 61 language and requirements for accreditation. In a word, it is unacceptable for an accreditation agency to be subordinate to or part of an organization that sets standards or certifies conformance to the standard. This requirement was not so clear before 2004. It is crystal clear now.
USGBC Is a Standard-Setting Body
Since USGBC and LEED ultimately depend for their credibility on compliance with international standards, it's worth getting into the detail. Measurement of anything requires standards, such as units of weight, money and temperature. Ideally an independent group convenes with representation from different stakeholders (e.g., buyers, sellers, government) and definitions of standards are agreed upon.
USGBC is such a standard-setting body. It created the LEED ratings of levels of green buildings (basic certification, silver, gold and platinum), for different types of buildings or groups of buildings. The new plan for outsourcing certification does not affect USGBC's committee-based process for developing LEED standards. USGBC is accredited by the American National Standards Institute (ANSI) as a standards developer and the LEED Accredited Professional program is ANSI-compliant. ANSI is a national member of the International Organization for Standardization, ISO, a network of national standards member institutes in 157 countries, based in Geneva, Switzerland.
ISO attempts to harmonize among national governmental standards institutes the standards for products or services in different business or industry sectors. These standards define specifications to be applied consistently in the classification of materials, in the manufacture and supply of products, in testing and analysis, in terminology and in the provision of services. ISO also provides guides for conformity assessment for suppliers, third-party certification and accreditation. ISO does not carry out certification itself, nor does it control the verifications used in the business sector of ISO 9000 and ISO 14000 management system standards. Some international groups have an advisory function such as the International Electrotechnical Commission, There are regional intercountry standards groups and each country or economy usually has a single national standards institute that is the core member of ISO.
Separating USGBC from the certification process will bring LEED into alignment with norms established by ISO that require standard-setting bodies to remain distinct entities, not combined with certification bodies in the same area. USGBC is not the only organization addressing the conflicting roles of standard-setting, certification and accreditation. The Forest Stewardship Council sets the standards for Rainforest Alliance Smartwood certification and its sister organization ASI accredits the Rainforest Alliance to certify that wood meets these standards. Separation of functions is crucial for USGBC because it won't be long before USGBC, like FSC, has watchdogs, investigative reporters and bloggers questioning the validity of some of its ratings. Separation of institutions makes it easier to identify problems and fix them. FSC and LEED are linked by the "points" that LEED standards allow for buildings using certified wood products. The problem for everyone is that the supply of certified wood is limited, an estimated 2 percent of the the U.S. lumber market and 8-10 percent of the world lumber market. This in turn could mean a long waiting time for lumber, higher prices or worst of all for FSC and USGBC counterfeit certifications. FSC seeks to capture 20 percent of the market by 2012. Wood vendors try to make it easy for buyers (builders or do-it-yourself homeowners) to buy certified wood by providing copies of fact sheets like this or this, which is best practice according to the International Social and Environmental Accreditation and Labeling ( ISEAL ) Alliance, the equivalent to ISO for global multi-stakeholder standard-setting initiatives like FSC.
Certification Bodies
Third-party certification bodies, also called registrars, are auditing organizations that issue certificates of conformance to a standard. The certificates can be issued to individuals (as in academic degrees or professional licenses), to companies, to facilities or to products, to show compliance with standards. Certification bodies derive their own credibility, consistency and quality by being subject to renewable accreditation.
Hundreds of certification bodies with staff literally in the hundreds of thousands stand ready (for a fee) to audit and certify against standards of all kinds. Their fees are justified by their long experience and the training that their auditors must undergo in order to qualify for certification work. By tapping into these bodies, USGBC will be able to clear the backlog in its certification pipeline when enough certifiers are trained to LEED standards. It could speed things up even more by licensing other organizations to accredit and train certification bodies. The economies of scale in accreditation are substantial and accreditation, like auditing, is labor-intensive and less profitable than consulting.
Standards for accredited certification bodies are set out in ISO/IEC Guide 17021:2006 and the earlier ISO/IEC Guide 65:1996 . Both these guides are surprisingly expensive ($112 for 26 pages, $58 for 8 pages). Consult at no charge a guide to the guide on accreditation by the International Accreditation Forum, an association of national accreditation agencies. A list of IAF members may be found on the website of the European Cooperation of Accreditation.
Accreditation Bodies
Accreditation is another word for licensing of qualified certification bodies. An accrediting authority private or governmental assesses the certification body on a regular basis to verify that the certification body is qualified to do its job, i.e., is objective, independent, with appropriately skilled personnel operating quality systems, so that the certification body will be able to determine reliably whether or not applicants for certification comply with the relevant standards.
Why is accreditation so important? Certification bodies need to be watched like the companies or products or buildings that they certify. Accreditation agencies are the answer to Juvenal's question quis custodiet ipsos custodes?
Remember the bankruptcies of Enron in 2001 and WorldCom in 2002? They were the two largest bankruptcies in world history. Both these companies were being audited by Arthur Andersen, which was not accredited. It was peer-reviewed by other accounting firms, but this clearly was and is inadequate. Andersen was benefiting from lucrative consulting contracts at the same time as it was auditing the two companies' financial statements. It was even then conventional wisdom that auditing suffers when consulting business is being conducted or under consideration at the same time. Andersen gave up its life as this message was hammered home after the WorldCom bankruptcy. Since July 2002, under the Sarbanes-Oxley Act, accounting firms that wish to audit public companies must be registered with the Public Company Accounting Oversight Board, which thereby serves as an accreditation agency (the PCAOB can always decide to revoke a firm's registration).
The International Accreditation Forum and ILAC are both aggregations of national bodies. The ISEAL Alliance is not. It is the specialized organization for environmental and social global standard-setters and accreditation bodies, of which the oldest is the U.S.-based International Organic Accreditation Service. IOAS is the sister organization to the organic agriculture standard-setting body, the International Federation of Organic Agriculture Movements (IFOAM), which has created both organic-agriculture norms and accreditation norms. ISEAL accreditation members, including the Forest Stewardship Council's ASI accreditation agency, are committed to compliance with the ISO standard ISO/IEC 17011 :2004 ($105 for 21 pages) for accreditation bodies. ISEAL has its own member code of good practice, which is downloadable from its website. To comply with ISO and ISEAL standards for accreditation agencies, the Forest Stewardship Council and Social Accountability International have each been separating out its accreditation function into a new organization ASI for FSC and Social Accountability Accreditation Services for SAI.
ISEAL has pioneered some innovations that are applicable to LEED standards. Interesting national and local recognitions of ISEAL member accreditation have been provided by governments. For example, in Italy, several regions (e.g., Venetia, Umbria, Lecce, Tuscana) and municipalities (Rome) have programs to encourage adherence to the SA8000 workplace sustainability standard. Regione Toscana (Tuscany, around Florence) was the first. Tuscany provides public education on SA8000 and provides grants to small businesses to enable them to implement SA8000 and to be certified for their compliance. These government-assisted programs have directly helped 300 Italian facilities become certified. Local governments have a stake in the branding of companies located within their borders. Regione Umbria (around Perugia) gives preference to otherwise qualified and cost-competitive bidders for government contracts that are certified to SAI's SA8000.
Summary
USGBC's move to open up its certification process to outside certification bodies, and to focus on accreditation, is a very good sign that the green-buildings program is going to catch up on its backlog and to be credible, so that the public will know whether or not the claimed standards are actually met. USGBC helps builders brand their buildings and co-branding organizations can have four different kinds of functions:
The USGBC plan seems to make it #1. GBCI's name implies #2, but it is morphing into #3, ceding #2 to qualified independent bodies. An accreditation agency, #3, should not be mixed with any of the other functions. Although USGBC and GBCI are legally distinct and have separate boards of directors , they share for the time being two senior managers. Ideally, all staff should be separate and all relationships between USGBC and GBCI should be arms-length and contractual.
USGBC is moving in the direction it needs to go. Another cheer when it moves closer to global norms.
Dr. Marlin is Principal of CSRNYC. He blogs on sustainability issues for Huffington Post, is an Adjunct Professor of Business Ethics at NYU's Stern School of Business and teaches in the CSR Certificate Program at the University of Geneva.
John Tepper Marlin, Ph.D.
Principal, CityEconomist, CSRNYC,
Adjunct Professor, NYU
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