EESI Experts Provide Comments on Green Community Standards

EESI Policy Director Ellen Vaughan and Policy Fellow Jonathan Herz provided comments to the Enterprise 2020 Green Communities Criteria. Enterprise Community Partners is a housing organization that delivers capital, develops programs, and advocates for policies “to create opportunity for low- and moderate-income people through affordable housing in diverse, thriving communities.” Enterprise’s Green Communities Criteria was the first U.S. green building framework to address the unique needs of the affordable housing sector. It is a voluntary program, last updated in 2015. According to the Enterprise website, “the 2020 Green Communities Criteria is looking at new ways to explore how the criteria can contribute to: improving resident health; strengthening homes’ resilience; managing developers’ upfront costs while improving building performance; and promoting equitable outcomes.” A notable update is its transition from a strict focus on energy efficiency to the “broader perspective of carbon neutrality.”

EESI’s expert comments on the 2020 Criteria, submitted on August 30, emphasize an integrated approach to achieve resilient and sustainable buildings and environmental and health-conscious development:

The Green Communities Criteria already represent one of the most comprehensive green building programs available, and the 2020 draft's additions make it even better. Resilience is particularly important, as more extreme weather events are testing the limits of current design standards and building codes, revealing dangerous vulnerabilities. On the issue of health, the 2020 draft covers every aspect of healthy building and community design. Unfortunately, the potential health and resilience benefits are undercut by making so many of them optional.

All of these optional requirements should be integrated into the planning, design, construction, and operations of the buildings and communities being created. The criteria's focus on the integrative design process is commendable until one realizes that the essence of the process—designing for multiple "performance goals" simultaneously and employing trade-offs to ensure cost effectiveness without sacrificing critical performance values—is at best undermined and at worst negated by the potential of leaving out important values, like health and resilience, because they are optional. The potential lack of funds or expertise in the local design community should not discourage consideration of health impacts and resilience throughout this process, so that all low-cost/no-cost, practicable features can be incorporated in the initial work and the remaining features easily incorporated as funds become available. The criteria state that city, municipal and county governments (e.g., local planning department, health department) can serve as valuable resources. They and all members of the community with appropriate expertise can be called upon to create a truly healthy green community.

Thank you for providing this opportunity to comment. Enterprise continues to do wonderful work!

Enterprise will release its response document in the fall of 2019.

Authors: Ellen Vaughan and Jonathan Herz.