Min Energy Peformance- 75 Energy Star Rating for EB O&M

The draft is proposing making the prerequisite for your Energy Star rating to be a minimum of 75. That is a 6 point jump from the previous requirement of a 69. That is very drastic, and a little extreme in our mind. We are working with many properties right now that are struggling to try and achieve LEED with ratings around 68-74. This would eliminate thousands of buildings, and we feel that this would greatly damage the LEED system. We understand that energy is a very large aspect of the LEED rating system, however it already greatly outweighs any other section of the rating system. Many properties’ energy star ratings are being affected by tenants installing large data centers that are beyond property control. Ratings have dropped, and properties are struggling to maintain high ratings. Not only that, but the Energy Star rating system is currently making changes, whereas effective in June 2012, properties can no longer claim data centers as a space type in an office building unless the data center is properly submetered, and actually energy data is input. Therefore, any buildings without proper submetering may be facing a dramatic drop in rating in June 2012. A building could be perfectly sustainable in every other way (great recycling rate, great water savings, etc.), but could be completely disqualified solely based on not having a high enough rating, or because they have a tenant with a large data center. Prerequisites are supposed to be considered reasonable to obtain. The points are where the real challenges should come into play, not the prereqs.