Mr. Chairman the achievement of energy efficiency in new and existing buildings is a complex endeavor. The technology involved is becoming more refined and sophisticated daily and many new procedures and items of equipment are currently under development. It is therefore imperative that any retrofit program remain flexible and responsive to these new developments as they occur. It is important that retrofit discussions reflect the need to concentrate our efforts on those projects which are most cost effective. Mr. Chairman, GSA is the leader in energy conservation in Thank you. That concludes my prepared remarks. I appreciate the opportunity to present our views and would be pleased to answer any questions relating to these bills or to GSA's initiatives in this area. Senator MORGAN. Gentlemen, we have a number of other witnesses. I am sorry if we have upset anyone's schedule, but I do thank you all for coming. Mr. Sigmund I. Gerber from DOD is next, for the record. He is the Director, Construction Standards and Design, Office, Assistant Secretary of Defense, Installations and Logistics, Department of Defense. Mr. Gerber, we are glad to have you here, and thank you for coming. STATEMENT OF SIGMUND I. GERBER, DIRECTOR, CONSTRUCTION STANDARDS AND DESIGN, OFFICE, ASSISTANT SECRETARY OF DEFENSE, INSTALLATIONS AND LOGISTICS, DEPARTMENT OF DEFENSE Mr. GERBER. Mr. Chairman, I have just a short statement. As you know, we were asked to address S. 2095. Since yesterday's discussions, I did have the opportunity to review both S. 2045 and S. 1392 and if the chairman will bear with me, I will try to cross-reference some of my comments on S. 2095 to the provisions of the other two bills. The Department of Defense appreciates the opportunity to comment on S. 2095 and to present our views on this important energy bill. The Department of Defense, as the result of close attention to the situation over the past several years, is keenly aware of the current energy problem and the great need not only to conserve existing energy sources, but also to develop, as soon as possible, new sources available within the United States. It has been Defense policy for over 15 years that our facilities would be designed and constructed to assure the minimum use of all utilities in order to achieve the most economical operation. Defense criteria have stressed the need for optimum insulation levels and we have been the leader in the Federal Government in our specific insulation requirements. Since 1956, the DOD has required all large heating plants, located in normal coal marketing areas, to be constructed so as to be convertible to the burning of coal. In 1967, Defense incorporated all existing instructions, directives, and other issuances relating to construction and alteration of all types of Defense facilities into a single publication entitled "DOD Construction Criteria Manual." This criteria manual establishes DOD policy on all aspects of construction including utilites and energy conservation. This manual was updated in 1972 and is currently being revised again to reflect changing technologies. We believe this manual meets the intent of section 4 of the bill S. 2095 as well as the comparable requirements of S. 2045 with respect to design, construction, and renovation of Defense buildings. For many years, Defense design criteria for new construction and major alterations have included significant numbers of energy conservation measures. While many of these measures have been included in new construction over the past 15 years, many other conservation measures were found not to be cost effective until the dramatic increases in the cost of all energy forms. In order to reduce the use of scarce fuels and to decrease the cost of utilities operations of Defense buildings, we have initiated an energy conservation investment program designed specifically to make existing buildings less energy intensive through a proposed $1.35 billion, 6-year retrofit program. This program includes only those readily identifiable projects which have a rapid amortization period. The Congress was requested to provide $138 million for fiscal year 1976 in the military construction and appropriation bills as a start of this program, and the average amortization period for these fiscal year 1976 projects is about 4 years. We believe this program meets the intent of section 5(a) (2) of S. 2095 as well as the comparable provisions of S. 1392. With specific regard to the use of solar energy, Defense testified in favor of Public Law 93-409, Solar Heating and Cooling Demonstration Act of 1974, and we are an integral part of the demonstration program. Subsequently, we were a major contributor to the implementing plan for that act which is embodied in the Energy Research and Development Administration's Report Number 23A, "The National Program for Solar Heating and Cooling." Currently, we are implementing our portion of this plan through the installation of 50 solar heating units in residences at some 14 Army, Navy, and Air Force installations. In addition, we are installing solar heating and cooling on a new administration and classroom building at Fort Hood, Tex. Plans are also being made to use solar heating and cooling on three Army Reserve facilities. Additionally, we are investigating the possibility of utilizing solar energy for the heating of domestic hot water for two dispensaries and nine dormitories. The Navy has just made a decision to put solar collectors on 600 family housing units that they just recently acquired from the Air Force when the Air Force disestablished the Air Force base near Orlando. While our experience from these efforts will make a contribution to the national program, it will also provide us with much needed information for evaluating the cost benefits to the Department of Defense from using solar heating and cooling systems on our new buildings, and where practical, for retrofitting existing buildings. The analysis which we would propose to conduct in order to determine whether solar heating and cooling systems should be used on Department buildings would, we feel, be compatible with the energy use analysis called for in S. 2095 and S. 2045. The major difficulty that we foresee in implementing the provisions of S. 2095 relating to the use of solar energy, and similar provisions of S. 2045, is that we do not feel that there is sufficient cost and performance data on solar heating and cooling systems available at this time. Such data is basic to the conduct of a meaningful life-cycle cost analysis. The national program for solar heating and cooling should provide us with the needed data on cost and performance of solar heating and cooling systems, and it is our considered opinion that full implementation of S. 2095 should be deferred until such data are available to permit us to conduct a sound life-cycle cost analysis. We expect that by the time sufficient cost and performance data are available, better knowledge on the future cost and availability of alternative sources of energy will also be available. As to our position on specific provisions of S. 2095, there are four major areas of concern. Section 3(a) (5) (B)(iii) appears to place an unfair burden on the building designer to determine the amount of energy required to produce and transport construction materials. Other witnesses have discussed this point also. This is beyond the designer's knowledge and responsibility, and would require decisions in areas in which he does not have expertise; namely, manufacturing and transportation. It is recommended that this section be delegated. On the other hand, if it is desirable to identify energy-intensive construction products, these should be identified by either the FEA or the Department of Commerce. Second, section 5(a) (1) would require submission to the Congress of an energy use analysis as part of normal procedures relating to construction. We interpret this to mean a submission at the time of the request for the military construction program, MCP. This would normally be prior to design completion, and the energy use analysis may have been started, but probably not completed. Further, such timing would be a burdensome and very costly task as there are from 600 to 900 line items in our annual construction program, and some energy studies exceed 100 pages in length. It is, therefore, suggested that the first part of this section be deleted and that on page 10, section 5(a)(1) begin with the word "incorporate" in line 21. Third, section 5(a) (2) requires, within 1 year, an inventory and energy use analysis of all existing buildings. The DOD has over 600,000 buildings worldwide, with about 20 percent of them overseas, and it would be impossible to comply with this section of the bill. Realitsically, even 10,000 buildings per year would be an overpowering task, even though many are of a repetitive nature. Furthermore, the absence of hard data on solar costs and operations would preclude a meaningful analysis. Accordingly, we recommend the deletion of this section. Lastly, section 5(c) (2) would require manufacturers to submit a detailed life-cycle energy cost analysis for major components of heating, ventilating, air-conditioning, lighting, and other energy-consuming systems for any building. Life-cycle costing is reflective of the particular design, exact use of the building, and of the particular equipment, local utilities costs, and the relationship to many other building components. We would suggest that such suppliers only be required to submit efficiency data for their components and systems or such other data which could be used to determine efficiencies for the particular product as it is actually utilized in a particular project. We strongly support the spirit and intent of S. 2095, S. 2045, and S. 1392, but would urge the committee to ease the requirements I have just spoken to. We would be pleased to respond to any questions the committee might have. Senator MORGAN. Thank you. We have a number of questions. Has DOD developed any guidelines similar to those established by GSA, that could be disseminated to other agencies? Mr. GERBER. Yes, sir. We do have very specific guidelines as well as guidelines based on performance criteria. We have not gone to the specificity of the Btu requirement per square foot per year such as the 55,000 figure that Mr. Meisen addressed because that is primarily addressed to general purpose administration-type buildings; and although Defense has some of those buildings, it is not the commonplace type of facility we have. Senator MORGAN. I was going to ask that. Are these primarily for military use? Mr. GERBER. Yes, sir. Senator MORGAN. What is your opinion regarding ASHRAE do you know what I am talking about, the Association of Heating, Refrigeration & Air-Conditioning? Mr. GERBER. Yes, sir. Senator MORGAN. What is your opinion with regard to their standards becoming a national standard? For example, could the content of DOD's criteria and the GSA guidelines be combined with these ASHRAE standards? Mr. GERBER. We do embrace and cross-reference ASHRAE requirements. It is the basic design criteria for most of our energy studies. It is a nationally and internationally recognized institution with high repute for their publications. Senator MORGAN. How much coordination have you done with the Bureau of Standards, ERDA, and other agencies? Mr. GERBER. We work very closely with them, and DOD technical representatives participate in all of the interagency considerations. Senator MORGAN. You talked a little about solar energy, noting the Navy had installed some in Air Force housing. Mr. GERBER. They had inherited those houses from the Air Force. Senator MORGAN. They would have to make some changes. I assume they couldn't just live in them, like the Air Force. What has their experience been with solar energy? Mr. GERBER. Actually, our experiences are too embryonic, and we don't have any feedback yet. They are still in the status of installation. Senator MORGAN. The National Observer, Washington Post, and other papers have recently published articles urging caution with respect to solar energy. Do you have any comment on this? Mr. GERBER. We are very optimistic? We do feel that it should be treated and handled with due consideration, be technically analyzed by experts in the field. We do feel that solar energy should, and will, play an important role in our energy consumption. Therefore, we do feel that we should be aggressive and take advantage of what solar energy can provide for us. Senator MORGAN. I agree. I think anytime you try to develop this kind of program, there will be some wasted money. Of course, there are some who will claim the Defense Department is good at wasting money, but I am not one of those. It would seem to me, however, that the Defense Department can afford to take a calculated risk much better than some others. I would like to see you pursue that. Mr. GERBER. We are pursuing it, sir. We are pursuing it very aggressively. We do have a common problem that all Federal agen |