This CIR is a follow-up to one made on 06.04.08 and answered on 06.25.08, regarding a campus-wide "Green Permit" program and compliance with the provisions for preferred LEV parking in an adjacent campus garage. The University\'s final details of the project provide a 20% discount for permits for vehicles achieving 37 mph or better, in accordance with the most current listing of the US Department of Energy (www.fueleconomy.gov). It does not, as the credit requires, use the ACEEE green score ratings as the criteria. As many vehicles with a minimum score of 40 do not have gas mileage estimates at or above the 37 mpg limit, we believe that the University\'s program is actually more stringent than the credit requires. Does USGBC agree with this assessment?
The applicant is seeking approval to use a standard of 37 miles per gallon (MPG) as an alternative reference standard for SSc4.3, Option 2, instead of the established American Council for an Energy Efficient Economy (ACEEE) vehicle rating score of 40 or greater. The proposed compliance path is not an acceptable alternative to the ACEEE ratings which uses a "life cycle" approach that attempts to capture the embodied energy of the vehicle by including mpg, emissions, vehicle weight etc. Note that NC v2.1 CIR Ruling dated 10/2/06 has approved the "US EPA Certified SmartWay Elite" http://www.epa.gov/SmartwayLogistics/consumer/vehicles.htm) as an acceptable alternative standard. This allowance is specific to the "Elite" designation (not simply "SmartWay"), which has been confirmed as equal to or more stringent than the ACEEE Green Score of 40. Applicable Internationally.