U.S. General Services Administration Comments

March 29, 2013

General Services Administration
Regulatory Secretariat (MVCB)
1275 First Street NE., 7th Floor
Washington, DC 20417

Mr. Bryan Steverson       bryan.steverson@gsa.gov

As the leading national trade organization for the U.S. geothermal heat pump industry, the Geothermal Exchange Organization (GEO) appreciates the opportunity to provide input to the U.S. General Services Administration’s request for additional input to better inform its recommendations to the Secretary of Energy regarding the federal government’s use of third party green building certification systems (EISA 436(h) Ad-Hoc Discussion Group).

GEO believes that GSA is on the right track in using third party certification systems to measure the design and performance of the federal government’s construction and major modernization projects. Such input will enhance your goal of an environmentally sound approach to the certification of green Federal buildings.

To provide a recommendation to the Secretary of Energy that will most likely encourage a comprehensive and environmentally sound approach to the certification of green Federal buildings, GEO suggests that GSA support the adoption of all three systems identified in their Request For Information, allowing Federal facility managers to utilize the system(s) most appropriate to their specific situations. This approach would create incentives for each of these organizations to continually evaluate their own methodologies and align their systems with actual “real-world” energy and environmental results.

We are pleased that the Energy section within the Green Building Initiative’s Green Globes system includes a subsection on renewable energy, which includes ground source heat pump systems and recognition of Energy Star designations, which rate geothermal heat pump systems as a “most efficient” technology.

And of course, any progress toward Net Zero buildings covered by the International Living Institute’s Living Building Challenge cannot be achieved without the multiples of efficiency offered by geothermal heat pumps in conjunction with solar PV panels on roofs.

However, third party systems like LEED sometimes give short shrift to the renewable energy capabilities of geothermal heat pump systems, which both the U.S. Department of Energy and the U.S. Environmental Protection Agency have called the most efficient and environmentally friendly heating and cooling method for buildings.

We urge GSA to take a critical look at how LEED rates geothermal heat pump systems, and seek improved understanding or their value by that organization.

Given that, GEO lauds GSA for developing its own standards for energy efficient heating and cooling systems, as evidenced by the agency’s P100 order that ensures geothermal heat pumps are considered for new construction and retrofits, based on a 20-year life cycle.

The industry appreciates GSA’s intuitive and forward thinking policy, which will go a long way toward saving taxpayer dollars on energy consumption, while slashing carbon emissions —and creating U.S. jobs in geothermal heat pump manufacture, distribution, sales, system design, excavation and drilling, and equipment installation.

If you have any questions or would like further information, please contact me.

Respectfully submitted,


Douglas A. Dougherty

President and CEO

GEO – The Geothermal Exchange Organization

Phone (217) 572-1261 | Email Doug@geoexchange.org