Historic buildings face hurdles for energy-law compliance
Some older structures may qualify for exemptions under Commerce’s rulesNovember 9th, 2023
Historic building owners may find there are additional challenges to meet Washington state’s upcoming energy-performance standards that nonhistorical building owners won’t have to contend with.
Yet some energy-efficiency experts note that there are exemptions for older properties in certain circumstances.
Justin Lee, senior program manager at Seattle-based McKinstry Co., says there are fewer opportunities to implement low- and no-cost energy improvements at historical buildings than are available at more modern buildings.
Newer buildings might be able to meet energy-performance standards with a few minor adjustments. McKinstry refers to those as performance improvements. For older buildings, the energy metrics will likely require significant modifications to meet compliance and are designated by McKinstry as investment-based improvements.
Building owners with properties that qualify for compliance with the new energy metrics can follow two paths to compliance—one based on performance and another based on investment, Lee says.
Compared with historic buildings, newer structures have more opportunities for performance-based energy improvements for low- or no-cost, which can be as simple as adjusting a building’s operating system for optimal energy performance, he says.
“It’s just a change in the controls,” explains Lee. “And those tend to have a really high return on investment.”
Performance-based upgrades work best for buildings that are either already under their target or close to it, Lee says.
Investment-based improvements are better suited for structures that are further away from a building’s energy targets and often require significant investment to meet compliance requirements, he says.
Greg Forsyth, director of capital projects for Spokane Public Schools, says the school district owns about 60 buildings and has hired Seattle-based FSi Engineers to provide a baseline assessment for about 35 of the district’s elementary, middle, and high school buildings.
The baseline results provided by FSi showed that the majority of SPS buildings are near Washington state’s energy-performance targets, Forsyth says. Minor adjustments and improvements could bring some buildings into compliance.
The analysis found only three buildings were noncompliant and could require capital investment to meet performance targets. He says of those identified buildings, one school has been scheduled for a significant remodel with an upcoming bond, and the other two schools aren’t so far off energy targets that they’d need major repairs.
“We put in a substantial amount of money for upkeep and maintenance to our existing buildings,” he says. “It doesn’t mean that we won’t have some work to do, but it does mean that we’ll have less work.”
Prior to the passage of the Clean Buildings Act, Spokane Public Schools followed building guidance from the Washington state Sustainable Protocol, Forsyth says. WSSP rules are similar to LEED standards but are managed through Washington state instead of through the U.S. Green Building Council. The district has a head start on performance-based improvements for most of its buildings by following the WSSP.
Spokane Public Schools owns and operates the 101-year-old Woodrow Wilson Elementary School, which required continued improvements over the last two years to replace the original exterior windows with efficient and historically correct graded windows, says Forsyth.
“Not only did (the windows) meet the needs of the historic society in look, but they met the energy standards in construction,” says Forsyth.
Additional guidance from Commerce is still needed to determine if scheduled, future updates at the district’s historic buildings will incur penalties for noncompliance by the state’s deadlines.
In the city of Spokane, building officials estimate the current inventory of buildings that will be subject to the new rules is about 400 buildings, says Kirstin Davis, communications manager for public works for the city of Spokane.
The city of Spokane has only assessed Tier 1-qualifying buildings in its portfolio, which are commercial buildings over 50,000 square feet in size, under the Clean Buildings Act.
Of those 400 buildings, the city owns three buildings that qualify for Tier 1 compliance, one of which has a historic designation, she says.
City-owned buildings in Tier 1 include the 161,000-square-foot Spokane City Hall building at 808 W. Spokane Falls Blvd.; the 68,000-square-foot Northeast Community Center, at 4001 N. Cook; and the 58,000-square-foot Central Service Center, at 915 N. Nelson.
City Hall is a historically designated building listed on the historic register as the Montgomery Ward building. It’s classified as a government office building in Eastern Washington which has an energy use intensity target of 69, according to data from McKinstry.
It’s unclear how close the City Hall building is to its intended energy-use target or what improvements would need to be made to the building to meet compliance requirements, Davis says.
“We’ve been getting a lot of details, but they’ve been changing so much that we don’t really have a path at this time,” she says. “Rulemaking doesn’t have to be done until Dec. 1, so we anticipate that there will be more changes coming as well.”
McKinstry has a history of revamping older properties such as the historic Spokane & Inland Empire Railroad Co. Building, known as the SIERR Building, located at 850 E. Spokane Falls Blvd., says Dale Silha, regional vice president in Spokane for the Seattle-based company.
The SIERR Building is 116 years old and first operated as a railcar repair and maintenance facility. After McKinstry’s $20 million renovation in 2010, the structure’s sustainable renovation now provides an energy-efficient home for office, classroom, and retail uses.
Silha says the SIERR Building has had extensive energy improvements completed already, including ground-source heating and cooling features, efficient lighting, and improved ventilation systems.
“That particular building is meeting the standards today at this point,” explains Silha.
Lee adds that the SIERR Building is atypical from many historic buildings due to its previous renovations, which likely will involve relatively minor adjustments to meet energy-compliance requirements.
There’s a lot of flexibility on the investment path to compliance, which McKinstry refers to as involving substantial capital improvements such as heating, ventilation, and air-conditioning equipment replacement, or roofing and lighting updates, says Lee.
On the investment-based path, building owners will need a Level 2 building audit to identify all of the methods that will increase energy performance and to determine which of the measures will be cost effective.
“You would do the audit, you do a life cycle cost assessment, and you come out with this subset of actions that are deemed cost effective. Once you’ve done all those measures, that meets your compliance for the state,” Lee says.
Many historic buildings are likely to follow the investment path to compliance, he adds.
Energy improvements to historic buildings aren’t required if those improvements would compromise the historical integrity of the structure, according to the Washington state Clean Buildings Performance Standard.
“You’re not going to be required to rip out functioning equipment, (but) to put in the best equipment when that equipment reaches its end of life,” Lee says.
Historic building owners face other hurdles to meet compliance metrics, including the limited availability of interior space to accommodate modern energy upgrades, Silha says.
Additionally, Lee adds that the cost to update a historic building is higher compared to nonhistorical properties.
For example, a boiler replacement in a 100-year-old structure will cost more than in a 30-year-old building because newer buildings typically have dedicated interior spaces for utility systems and piping.
“To some degree, we’re trying to fight the building envelope and trying to fight the space,” says Silha.
As for exterior energy-efficiency measures to older buildings, Lee says a stopgap has been incorporated into the rules that negates any compliance measure that would compromise the historical integrity of a building.
If an audit identifies that single-pane leaded glass windows are wasting energy at a building, and if an analysis determines the improvements would damage the historical integrity of the property, then the state won’t require window replacements.
Forsyth says that regardless of the costs for improvements, the district intends to continue updating buildings as scheduled in future bonds to provide better learning environments.
“When we apply our bond construction dollars, we want to make better educational spaces, of course. But we want our buildings to operate highly efficiently, so we pay less per month to operate the buildings,” says Forsyth.
With about 2 1/2 years left until the first compliance deadline for the Clean Buildings Act arrives, building owners should be aware of exemptions that could apply to historic properties.
To qualify for a historic exemption, first, a qualified historic preservationist must evaluate the property to identify the energy-efficiency measures that could compromise the historic integrity of the property, Washington state performance standard guidelines state.
Then, building owners will be required to provide documentation to Commerce of their property’s historic significance or eligibility, and complete any other energy-efficiency measures identified in the audit that don’t modify the historical aspects of their buildings.
Even if all the improvements identified in an energy audit were accomplished, for some historic buildings, the energy-use target still won’t be met.
“The overall intent is to make sure that we’re doing the kind of things that make sense to do,” Lee says.