LA Multifamily Properties: Do you have a plan for Compliance with EBEWE?
All buildings over 20,000 sq feet must be benchmarked, audited & retrocommissioned
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With such a heavy focus on our industries response to COVID, it may be easy to forget about the City's of Los Angeles’ Existing Buildings Energy & Water Efficiency (EBEWE) Program. While deadlines have been suspended for now, it is important to plan for compliance with this ordinance which was established in 2016 (LA Municipal Code Section 91.9701, Ordinance No. 184674) and is administered by the Department of Building and Safety (LADBS). For updates on the status of the EBEWE Deadline suspension, follow this link.
The EBEWE ordinance requires that owners of buildings subject to the Ordinance, to annually register their building (includes pay fees) and file a benchmark report of energy and water usage for their buildings for the Compliance Year. The EBEWE data set includes the Compliance Year, Building Address, Compliance Status, various energy and water use benchmark data, and the last 3 digits of the Assessor Identification Number (AIN).
There are three steps for compliance for buildings subject to the ordinance, which includes Multifamily properties. It is important to plan for compliance, this guide can help develop that plan. If your property needs help, please feel free to reach out to me directly and I will be happy to help if I can.
Benchmark - setup, enter and import data into Energy Star
A benchmarking report (generated by the ENERGY STAR Portfolio Manager software), summarizing the annual energy and water performance of a building, is now required to be certified by a licensed professional engineer and submitted annually for all privately owned buildings 20,000 sq. ft. and above.
Exemptions may be obtained if:
Unoccupied with no certificate of occupancy or under renovation for entire measurement year.
Demolition permit issued AND demolition work has commenced on or before benchmarking report is due for compliance.
No energy or water service to building for ENTIRE benchmark year.
Note: The square footage requirement pertains to an entire building, not a parcel. i.e. multiple buildings on a single parcel added together exceeding 20,000 sq. ft. would not require compliance.
Audit - complete a Level 2 Energy & Water Audit
All buildings over 20,000 sq. ft. must have a minimum of a Level 2 Energy & Water Audit completed every 5 years and certified by a CA Licensed professional engineer.
What is Level 2 Energy & Water Audit?
An ASHRAE Level 2 audit provides in-depth identification and documentation of a building’s energy and water-use equipment, operations and calculated energy and water use compared to detailed historical (baseline) consumption. This audit examines existing conditions to pinpoint operational and capital improvements for energy and water efficiency.
Note: An ASHRAE Level 3 audit will also meet the requirements of the EBEWE. The Level 3 audit is significantly more involved, using detailed building and equipment simulation software to more accurately model projected utility savings along and capital costs. This is often referred to an investment grade audit used for larger, more complex buildings or campuses where financial risks are higher.
Retrocommissioning - complete corrections identified in the Level 2 Energy & Water Audit
All buildings over 20,000 sq. ft. and subject to energy and water audits are also required to complete a professional assessment of the maintenance and repairs necessary to correct issues identified in the Level 2 Energy and Water Audit, including verification of completion of said maintenance and repairs.
Exemptions to Audit & Retrocommission requirements:
It is important to evaluate any property subject to comply with EBEWE to determine if the building either needs to complete the audit and related retrocommission or determine if the building is exempt.
Buildings are exempt from Audit & Retrocommission requirements under the following conditions:
Energy:
1. The building has already received Energy Star Certification from the EPA for the year of the building’s compliance due date, or for two of the three years preceding the building’s compliance due date.
2. For buildings not eligible to receive an Energy Star score, the energy performance of the building must be 25% better than the national median energy performance of similar buildings. Energy performance calculations and comparisons are generated by Energy Star Portfolio Manager.
3. A CA licensed engineers certifies that the building has reduced its weather normalized source Energy Use Intensity (EUI) by 15% when compared to the five years before a building’s compliance due date.
4. A building without a central cooling system has completed four of six energy efficiency measures listed in the EBEWE guidelines within the 5 year compliance cycle being reported.
Water:
1. A CA licensed engineer certifies that the building has reduced its water use intensity by at least 20% (compared to the five years prior to the building’s compliance due date).
2. Buildings without central cooling systems that have completed two of three water efficiency measures listed in the EBEWE guidelines within the 5 year compliance cycle being reported.
3. A CA licensed engineer certifies that the building’s water use conforms to the LA Municipal and Title 24 Code in effect at any time during the five year compliance cycle.
4. The building is new and has been occupied for less than five years from its occupancy date based on the Temporary or final Certificate of Occupancy.
The final step, is to repeat, continue to monitor energy usage and benchmark performance to identify performance creep before it becomes an issue. This is where a produce such as EnergyScoreCards really helps, especially at scale. Continuous monitoring and identification of issues as they occur help retain the savings in energy consumption and cost.
Following the four-step process recommended by EnergyStar is the path to compliance and continuous improvement and Conservice can help develop that plan. Please reach out to me directly if you need help in developing that plan.
For a complete explanation of the EBEWE Program, including reporting requirements, please visit LADBS' EBEWE site at http://www.ladbs.org/services/green-building-sustainability/existing-buildings-energy-water-efficiency-program.
Stay well!
Chris Laughman is the ThirtyNine Blog author, a blog dedicated to reducing the impact of the built environment. When not blogging, Chris is helping the real estate industry minimize energy and water impact as the Vice President of Sustainability for Conservice, the Utility Experts. Whether Multifamily, Single Family, Student Housing, Commercial, or Military, we simplify utility billing and expense management by doing it for you. Our insight into your utility consumption provides an opportunity to identify risks. Leveraging innovation and experience, we ignite solutions with tangible impacts and track performance to ensure the trendline stays laser-focused on the goal. At Conservice, we have developed a true bill-to-boardroom solution to help truly make a difference. We have before us a tremendous opportunity. Standing shoulder to shoulder, we will get this done. Contact me at claughman@conservice.com for more information.
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