ATTACHMENT 14

memorandum

to:                  J.B. Culpepper, Planning Director

from:            John Richardson, Long Range/Sustainability Planner

subject:       South Grove Energy Management Plan

date:             March 4, 2008

PURPOSE

This memorandum is intended to provide detailed background information and recommended stipulations for the applicant’s latest version of the South Grove Energy Management Plan.

BACKGROUND

The applicant has most recently developed the second version of an Energy Management Plan (EMP) which describes their intent to integrate energy efficiency into both site design and homeowners’ association (HOA) documents in order to monitor construction practices and encourage ongoing operating efficiencies.  The applicant also notes a commitment to building homes which are at least 20% more energy efficient than the baseline requirements of the ASHRAE standard for this type of housing product (i.e., single family).  According to the EMP, this will be achieved through HOA monitoring as well as sealed engineering calculations which will certify the performance of each home and be submitted to both the Planning and Inspections departments when building construction permits are sought.

The EMP describes a strong involvement by the HOA in working towards energy efficiency and conservation through construction as well as site design.  For example, it is noted that the HOA will work to minimize lawn area installations and irrigation system sizes.  Similarly, it is stated that the HOA will encourage the use of rainwater cisterns in a manner which is consistent with the development’s continuing goals of energy efficiency and conservation.  In light of the current drought conditions, staff finds these potential measures to be both positive and in the vein of a more comprehensive form of sustainable development.

As noted above, the applicant has submitted two drafts of the EMP to staff.  Prior to the submission of the first draft, staff met with the applicant to review the Council policy pertaining to energy efficiency and Energy Management Plans.  Additionally, the staff provided the applicant with a suggested framework for developing an EMP which is consistent with the guidance given to other recent applicants and provides a possible structure that addresses the specific expectations of the Council policy found in Resolution 2007-04-23/R9, a policy revised from Resolution 2001-11-12/R20. 

As part of staff’s evaluation of the first EMP, a series of comments were provided to the applicant describing some of the suggested modifications and considerations for the Plan.  Such comments generally included the following:

• A request that the applicant put the EMP into a framework which is more consistent with that of other recent applicant’s EMPs.  At present, the EMP is largely a narrative which does not call attention to specific methods, measures/elements or stipulations like other recent EMPs have done.  Placing the content of the EMP in staff’s suggested framework (which the applicant has a copy of) will allow both staff and the review bodies to more easily determine what can be expected versus what might only be intended.  Staff also believes that the suggested framework will highlight the applicant’s intended measures more clearly and allow for better comparison with existing and future EMPs.
• A request that the applicant explain the mechanism which demonstrates that each home will achieve a 20% greater level of energy efficiency as compared the baseline requirements of the ASHRAE standard for this type of housing product.  Staff conveyed to the applicant that ENERGY STAR qualified homes, the type of certification that may be sought after for each home in the development, do not necessarily achieve the applicant’s 20% target through the certification process.
• A request that the applicant acknowledge and describe some consideration towards other components of the Council energy efficiency policy which have not been expressly noted in the EMP, such as:
• The production or offset purchase of renewable energy sources through the NC GreenPower program; and
• Assurances of indoor air quality, adequate access to natural lighting and the allowance of renewable energy.
• A request that the applicant consider, in addition to the ENERGY STAR program, other green building programs such as LEED for Homes or NC Healthy Built Homes which can require higher baseline energy efficiencies (above ENERGY STAR) and also provide a more comprehensively sustainable form of development.

DISCUSSION

In response to the comments above, the applicant appeared to make only one modification to the original EMP.  This change is found at the end of the document and describes the mechanism for how builders will provide evidence for a 20% energy efficiency improvement above ASHRAE standards (noted above at the end of the first paragraph in background section of this memorandum).  Consequently, staff believes it will be important for the applicant to agree to the stipulations shown in the recommendation section of this memorandum below.  We believe the applicant’s success at complying with these recommended stipulations will better demonstrate the intent of the Council policy regarding energy efficiency and Energy Management Plans.  Furthermore, staff would submit that the recommended stipulations are reasonable in that they are designed to provide for a more complete Energy Management Plan that is consistent with what other applicants have recently provided to staff.

RECOMMENDATION

We recommend that the following stipulations be required of the applicant.

1. The applicant will revise the Energy Management Plan prior to the issuance of a Zoning Compliance Permit, so as to put t in a framework that is more consistent with other plans submitted to date.  As part of this revision, commitments to certain conservation measures by the applicant must be shown as stipulations within the Energy Management Plan.  The type and number of commitments represented through these stipulations will be at the applicant’s discretion; however, staff will provide additional comments if these commitments fall short of the Council policy.  In order to revise the plan, the applicant can meet with staff to discuss the framework and/or use the staff handout for guidance.
2. As part of the applicant’s revisions to the framework of the Energy Management Plan, the applicant must describe some consideration towards other components of the Council energy efficiency policy which have not been expressly noted in the current form of the EMP, such as:
1. The production or offset purchase of renewable energy sources through the NC GreenPower program; and
2. Assurances of indoor air quality, adequate access to natural lighting and the allowance of renewable energy.
3. Because home energy rating specialists who work closely with builders can most accurately determine the energy efficiency of a home once it is built, the applicant should modify the suggested mechanism for assuring 20% greater energy efficiency to indicate that sealed engineering calculations which certify the performance of each home shall be submitted to both the Planning and Inspections departments no more than 30 days after the Certificate of Occupancy (CO) has been issued.  This adjusts the suggested point of review for sealed engineering calculations from the permitting stage to approximately one month after the CO stage.