In this September 2011 letter to the Department of Energy (DOE), NMHC/NAA voiced concerns over a proposed National Asset Rating Program for Commercial Buildings (AR Program). The AR Program would rate new and existing buildings on their expected energy performance based on the building’s physical characteristics or “as-built” features, but fails to incorporate operational considerations or actual utility data.
NMHC/NAA question the market need for another energy measurement program, when well-established governmental programs such as EPA’s Energy Star as well as numerous privately administered ratings exist. Instead, we suggest that reinvestment in existing programs is a more effective and resource-efficient path to achieving energy-efficiency goals.
