44
SUSTAINABILITY ACCOUNTING STANDARD INFRASTRUCTURE SECTOR © 2016 SASB Sustainable Industry Classification System (SICS ) #IF0402 Prepared by the Sustainability Accounting Standards Board ® March 2016 Provisional Standard www.sasb.org REAL ESTATE OWNERS, DEVELOPERS & INVESTMENT TRUSTS Sustainability Accounting Standard

Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

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Page 1: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

SUSTAINABILITY ACCOUNTING STANDARD

INFRASTRUCTURE SECTOR

copy 2016 SASBtrade

Sustainable Industry Classification Systemtrade (SICStrade) IF0402

Prepared by the

Sustainability Accounting Standards Boardreg

March 2016

Provisional Standard

wwwsasborg

REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

Sustainability Accounting Standard

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

SUSTAINABILITY ACCOUNTING STANDARDS BOARD

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTSSustainability Accounting Standard

The information text and graphics in this publication (the ldquoContentrdquo) is owned by Sustainability Accounting Standards Board All rights reserved You may use the Content only for non-commercial informational or scholarly use provided that you keep intact all copyright and other proprietary notices related to the Content and that you make no modifications to the Content The Content may not be otherwise disseminated distributed republished reproduced or modified without the prior written permission of Sustainability Accounting Standards Board To request permission please contact us at infosasborg

About SASB

The Sustainability Accounting Standards Board (SASB) provides sustainability accounting standards for use by

publicly-listed corporations in the US in disclosing material sustainability information for the benefit of investors

and the public SASB standards are designed for disclosure in mandatory filings to the Securities and Exchange

Commission (SEC) such as the Form 10-K and 20-F SASB is an independent 501(c)3 non-profit organization

Through 2016 SASB is developing standards for 79 industries in 10 sectors

SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

Table of Contents

Introduction 1

Purpose amp Structure 1

Industry Description 1

Guidance for Disclosure of Sustainability Topics in SEC filings 2

Guidance on Accounting of Sustainability Topics 4

Users of the SASB Standards 5

Scope of Disclosure 5

Reporting Format 5

Timing 8

Limitations 8

Forward Looking Statements 8

Sustainability Disclosure Topics amp Accounting Metrics 9

Energy Management 11

Water Management 23

Management of Tenant Sustainability Impacts 33

Climate Change Adaptation 38

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 1

INTRODUCTION

Purpose amp Structure

This document contains the SASB Sustainability Accounting Standard (SASB Standard) for the Real Estate Owners

Developers amp Investment Trusts industry

SASB Sustainability Accounting Standards are comprised of (1) disclosure guidance and (2) accounting

standards on sustainability topics for use by US and foreign public companies in their annual filings (Form 10-

K or 20-F) with the US Securities and Exchange Commission (SEC) To the extent relevant SASB Standards may

also be applicable to other periodic mandatory filings with the SEC such as the Form 10-Q Form S-1 and Form

8-K

SASB Standards identify sustainability topics at an industry level which may constitute material informationmdash

depending on a companyrsquos specific operating contextmdashfor a company within that industry SASB Standards are

intended to provide guidance to company management which is ultimately responsible for determining which

information is material and should therefore be included in its Form 10-K or 20-F and other periodic SEC filings

SASB Standards provide companies with standardized sustainability metrics designed to communicate performance

on industry level sustainability topics When making disclosure on sustainability topics companies can use SASB

Standards to help ensure that disclosure is standardized and therefore decision-useful relevant comparable and

complete

SASB Standards are intended to constitute ldquosuitable criteriardquo as defined by AT 10123 - 321 and referenced in AT

7012 as having the following attributes

bull ObjectivitymdashCriteria should be free from bias

bull MeasurabilitymdashCriteria should permit reasonably consistent measurements qualitative or quantitative

of subject matter

bull CompletenessmdashCriteria should be sufficiently complete so that those relevant factors that would alter

a conclusion about subject matter are not omitted

bull RelevancemdashCriteria should be relevant to the subject matter

Industry Description

The Real Estate Owners Developers amp Investment Trusts industry (the ldquoReal Estate industryrdquo) is composed of

companies that own develop and generally operate income-producing real estate assets Companies in this

industry are commonly structured as real estate investment trusts (REITs) and operate in a wide range of segments

within the real estate industry including residential retail office health care industrial and hotel properties REITs

typically focus on the direct ownership of real estate assets thereby providing investors with the opportunity to

obtain real estate exposure without direct asset ownership and management Although REITs are often

1 httppcaobusorgStandardsAttestationPagesAT101aspxat_101_fn7 2 httppcaobusorgStandardsAttestationPagesAT701aspx

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 2

concentrated in one segment of the real estate industry many REITs are diversified through investment in multiple

property types

For tax purposes real estate companies in the US often prefer to be structured as REITs To be classified as a REIT

companies must maintain most of their assets in real estate derive most income from these assets and distribute a

minimum threshold of their annual taxable income to shareholders as dividends among other requirements Most

US-listed companies in the industry operate exclusively within the US while some companies have broadened

their real estate portfolio exposure internationally

Guidance for Disclosure of Sustainability Topics in SEC Filings

1 Industry-Level Sustainability Topics

For the Real Estate Owners Developers amp Investment Trusts industry SASB has identified the following

sustainability disclosure topics

bull Energy Management

bull Water Management

bull Management of Tenant Sustainability Impacts

bull Climate Change Adaptation

2 Company-Level Determination and Disclosure of Material Sustainability Topics

Sustainability disclosures are governed by the same laws and regulations that govern disclosures by securities issuers

generally According to the US Supreme Court a fact is material if in the event such fact is omitted from a

particular disclosure there is ldquoa substantial likelihood that the disclosure of the omitted fact would have been

viewed by the reasonable investor as having significantly altered the lsquototal mixrsquo of the information made

availablerdquo34

SASB has attempted to identify those sustainability topics that are reasonably likely to have a material effect on the

financial condition or operating performance of companies within each SICS industry SASB recognizes however

that each company is ultimately responsible for determining what information should be disclosed within the

context of Regulation S-K and other guidance

Regulation S-K which sets forth certain disclosure requirements associated with Form 10-K and other SEC filings

requires companies among other things to describe in the Managementrsquos Discussion and Analysis of Financial

Condition and Results of Operations (MDampA) section of Form 10-K ldquoany known trends or uncertainties that have

had or that the registrant reasonably expects will have a material favorable or unfavorable impact on net sales or

revenues or income from continuing operations If the registrant knows of events that will cause a material change

in the relationship between costs and revenues (such as known future increases in costs of labor or materials or price

increases or inventory adjustments) the change in the relationship shall be disclosedrdquo

3 TSC Industries v Northway Inc 426 US 438 (1976)4 CFR 229303(Item 303)(a)(3)(ii)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE ltFEFF005400610074006f0020006e006100730074006100760065006e00ed00200070006f0075017e0069006a007400650020006b0020007600790074007600e101590065006e00ed00200064006f006b0075006d0065006e0074016f002000410064006f006200650020005000440046002c0020006b00740065007200e90020007300650020006e0065006a006c00e90070006500200068006f006400ed002000700072006f0020006b00760061006c00690074006e00ed0020007400690073006b00200061002000700072006500700072006500730073002e002000200056007900740076006f01590065006e00e900200064006f006b0075006d0065006e007400790020005000440046002000620075006400650020006d006f017e006e00e90020006f007400650076015900ed007400200076002000700072006f006700720061006d0065006300680020004100630072006f00620061007400200061002000410064006f00620065002000520065006100640065007200200035002e0030002000610020006e006f0076011b006a016100ed00630068002egt13 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB ltFEFF05D405E905EA05DE05E905D5002005D105D405D205D305E805D505EA002005D005DC05D4002005DB05D305D9002005DC05D905E605D505E8002005DE05E105DE05DB05D9002000410064006F006200650020005000440046002005D405DE05D505EA05D005DE05D905DD002005DC05D405D305E405E105EA002005E705D305DD002D05D305E405D505E1002005D005D905DB05D505EA05D905EA002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002E05D005DE05D905DD002005DC002D005000440046002F0058002D0033002C002005E205D905D905E005D5002005D105DE05D305E805D905DA002005DC05DE05E905EA05DE05E9002005E905DC0020004100630072006F006200610074002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002Egt13 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR ltFEFF004200720075006b00200064006900730073006500200069006e006e007300740069006c006c0069006e00670065006e0065002000740069006c002000e50020006f0070007000720065007400740065002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740065007200200073006f006d00200065007200200062006500730074002000650067006e0065007400200066006f00720020006600f80072007400720079006b006b0073007500740073006b00720069006600740020006100760020006800f800790020006b00760061006c0069007400650074002e0020005000440046002d0064006f006b0075006d0065006e00740065006e00650020006b0061006e002000e50070006e00650073002000690020004100630072006f00620061007400200065006c006c00650072002000410064006f00620065002000520065006100640065007200200035002e003000200065006c006c00650072002000730065006e006500720065002egt13 POL 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 PTB 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 RUM ltFEFF005500740069006c0069007a00610163006900200061006300650073007400650020007300650074010300720069002000700065006e007400720075002000610020006300720065006100200064006f00630075006d0065006e00740065002000410064006f006200650020005000440046002000610064006500630076006100740065002000700065006e0074007200750020007400690070010300720069007200650061002000700072006500700072006500730073002000640065002000630061006c006900740061007400650020007300750070006500720069006f006100720103002e002000200044006f00630075006d0065006e00740065006c00650020005000440046002000630072006500610074006500200070006f00740020006600690020006400650073006300680069007300650020006300750020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e00300020015f00690020007600650072007300690075006e0069006c006500200075006c0074006500720069006f006100720065002egt13 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 2: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

SUSTAINABILITY ACCOUNTING STANDARDS BOARD

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTSSustainability Accounting Standard

The information text and graphics in this publication (the ldquoContentrdquo) is owned by Sustainability Accounting Standards Board All rights reserved You may use the Content only for non-commercial informational or scholarly use provided that you keep intact all copyright and other proprietary notices related to the Content and that you make no modifications to the Content The Content may not be otherwise disseminated distributed republished reproduced or modified without the prior written permission of Sustainability Accounting Standards Board To request permission please contact us at infosasborg

About SASB

The Sustainability Accounting Standards Board (SASB) provides sustainability accounting standards for use by

publicly-listed corporations in the US in disclosing material sustainability information for the benefit of investors

and the public SASB standards are designed for disclosure in mandatory filings to the Securities and Exchange

Commission (SEC) such as the Form 10-K and 20-F SASB is an independent 501(c)3 non-profit organization

Through 2016 SASB is developing standards for 79 industries in 10 sectors

SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

Table of Contents

Introduction 1

Purpose amp Structure 1

Industry Description 1

Guidance for Disclosure of Sustainability Topics in SEC filings 2

Guidance on Accounting of Sustainability Topics 4

Users of the SASB Standards 5

Scope of Disclosure 5

Reporting Format 5

Timing 8

Limitations 8

Forward Looking Statements 8

Sustainability Disclosure Topics amp Accounting Metrics 9

Energy Management 11

Water Management 23

Management of Tenant Sustainability Impacts 33

Climate Change Adaptation 38

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 1

INTRODUCTION

Purpose amp Structure

This document contains the SASB Sustainability Accounting Standard (SASB Standard) for the Real Estate Owners

Developers amp Investment Trusts industry

SASB Sustainability Accounting Standards are comprised of (1) disclosure guidance and (2) accounting

standards on sustainability topics for use by US and foreign public companies in their annual filings (Form 10-

K or 20-F) with the US Securities and Exchange Commission (SEC) To the extent relevant SASB Standards may

also be applicable to other periodic mandatory filings with the SEC such as the Form 10-Q Form S-1 and Form

8-K

SASB Standards identify sustainability topics at an industry level which may constitute material informationmdash

depending on a companyrsquos specific operating contextmdashfor a company within that industry SASB Standards are

intended to provide guidance to company management which is ultimately responsible for determining which

information is material and should therefore be included in its Form 10-K or 20-F and other periodic SEC filings

SASB Standards provide companies with standardized sustainability metrics designed to communicate performance

on industry level sustainability topics When making disclosure on sustainability topics companies can use SASB

Standards to help ensure that disclosure is standardized and therefore decision-useful relevant comparable and

complete

SASB Standards are intended to constitute ldquosuitable criteriardquo as defined by AT 10123 - 321 and referenced in AT

7012 as having the following attributes

bull ObjectivitymdashCriteria should be free from bias

bull MeasurabilitymdashCriteria should permit reasonably consistent measurements qualitative or quantitative

of subject matter

bull CompletenessmdashCriteria should be sufficiently complete so that those relevant factors that would alter

a conclusion about subject matter are not omitted

bull RelevancemdashCriteria should be relevant to the subject matter

Industry Description

The Real Estate Owners Developers amp Investment Trusts industry (the ldquoReal Estate industryrdquo) is composed of

companies that own develop and generally operate income-producing real estate assets Companies in this

industry are commonly structured as real estate investment trusts (REITs) and operate in a wide range of segments

within the real estate industry including residential retail office health care industrial and hotel properties REITs

typically focus on the direct ownership of real estate assets thereby providing investors with the opportunity to

obtain real estate exposure without direct asset ownership and management Although REITs are often

1 httppcaobusorgStandardsAttestationPagesAT101aspxat_101_fn7 2 httppcaobusorgStandardsAttestationPagesAT701aspx

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 2

concentrated in one segment of the real estate industry many REITs are diversified through investment in multiple

property types

For tax purposes real estate companies in the US often prefer to be structured as REITs To be classified as a REIT

companies must maintain most of their assets in real estate derive most income from these assets and distribute a

minimum threshold of their annual taxable income to shareholders as dividends among other requirements Most

US-listed companies in the industry operate exclusively within the US while some companies have broadened

their real estate portfolio exposure internationally

Guidance for Disclosure of Sustainability Topics in SEC Filings

1 Industry-Level Sustainability Topics

For the Real Estate Owners Developers amp Investment Trusts industry SASB has identified the following

sustainability disclosure topics

bull Energy Management

bull Water Management

bull Management of Tenant Sustainability Impacts

bull Climate Change Adaptation

2 Company-Level Determination and Disclosure of Material Sustainability Topics

Sustainability disclosures are governed by the same laws and regulations that govern disclosures by securities issuers

generally According to the US Supreme Court a fact is material if in the event such fact is omitted from a

particular disclosure there is ldquoa substantial likelihood that the disclosure of the omitted fact would have been

viewed by the reasonable investor as having significantly altered the lsquototal mixrsquo of the information made

availablerdquo34

SASB has attempted to identify those sustainability topics that are reasonably likely to have a material effect on the

financial condition or operating performance of companies within each SICS industry SASB recognizes however

that each company is ultimately responsible for determining what information should be disclosed within the

context of Regulation S-K and other guidance

Regulation S-K which sets forth certain disclosure requirements associated with Form 10-K and other SEC filings

requires companies among other things to describe in the Managementrsquos Discussion and Analysis of Financial

Condition and Results of Operations (MDampA) section of Form 10-K ldquoany known trends or uncertainties that have

had or that the registrant reasonably expects will have a material favorable or unfavorable impact on net sales or

revenues or income from continuing operations If the registrant knows of events that will cause a material change

in the relationship between costs and revenues (such as known future increases in costs of labor or materials or price

increases or inventory adjustments) the change in the relationship shall be disclosedrdquo

3 TSC Industries v Northway Inc 426 US 438 (1976)4 CFR 229303(Item 303)(a)(3)(ii)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS 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ltFEFF005400610074006f0020006e006100730074006100760065006e00ed00200070006f0075017e0069006a007400650020006b0020007600790074007600e101590065006e00ed00200064006f006b0075006d0065006e0074016f002000410064006f006200650020005000440046002c0020006b00740065007200e90020007300650020006e0065006a006c00e90070006500200068006f006400ed002000700072006f0020006b00760061006c00690074006e00ed0020007400690073006b00200061002000700072006500700072006500730073002e002000200056007900740076006f01590065006e00e900200064006f006b0075006d0065006e007400790020005000440046002000620075006400650020006d006f017e006e00e90020006f007400650076015900ed007400200076002000700072006f006700720061006d0065006300680020004100630072006f00620061007400200061002000410064006f00620065002000520065006100640065007200200035002e0030002000610020006e006f0076011b006a016100ed00630068002egt13 DAN 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HEB 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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Page 3: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS

Table of Contents

Introduction 1

Purpose amp Structure 1

Industry Description 1

Guidance for Disclosure of Sustainability Topics in SEC filings 2

Guidance on Accounting of Sustainability Topics 4

Users of the SASB Standards 5

Scope of Disclosure 5

Reporting Format 5

Timing 8

Limitations 8

Forward Looking Statements 8

Sustainability Disclosure Topics amp Accounting Metrics 9

Energy Management 11

Water Management 23

Management of Tenant Sustainability Impacts 33

Climate Change Adaptation 38

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 1

INTRODUCTION

Purpose amp Structure

This document contains the SASB Sustainability Accounting Standard (SASB Standard) for the Real Estate Owners

Developers amp Investment Trusts industry

SASB Sustainability Accounting Standards are comprised of (1) disclosure guidance and (2) accounting

standards on sustainability topics for use by US and foreign public companies in their annual filings (Form 10-

K or 20-F) with the US Securities and Exchange Commission (SEC) To the extent relevant SASB Standards may

also be applicable to other periodic mandatory filings with the SEC such as the Form 10-Q Form S-1 and Form

8-K

SASB Standards identify sustainability topics at an industry level which may constitute material informationmdash

depending on a companyrsquos specific operating contextmdashfor a company within that industry SASB Standards are

intended to provide guidance to company management which is ultimately responsible for determining which

information is material and should therefore be included in its Form 10-K or 20-F and other periodic SEC filings

SASB Standards provide companies with standardized sustainability metrics designed to communicate performance

on industry level sustainability topics When making disclosure on sustainability topics companies can use SASB

Standards to help ensure that disclosure is standardized and therefore decision-useful relevant comparable and

complete

SASB Standards are intended to constitute ldquosuitable criteriardquo as defined by AT 10123 - 321 and referenced in AT

7012 as having the following attributes

bull ObjectivitymdashCriteria should be free from bias

bull MeasurabilitymdashCriteria should permit reasonably consistent measurements qualitative or quantitative

of subject matter

bull CompletenessmdashCriteria should be sufficiently complete so that those relevant factors that would alter

a conclusion about subject matter are not omitted

bull RelevancemdashCriteria should be relevant to the subject matter

Industry Description

The Real Estate Owners Developers amp Investment Trusts industry (the ldquoReal Estate industryrdquo) is composed of

companies that own develop and generally operate income-producing real estate assets Companies in this

industry are commonly structured as real estate investment trusts (REITs) and operate in a wide range of segments

within the real estate industry including residential retail office health care industrial and hotel properties REITs

typically focus on the direct ownership of real estate assets thereby providing investors with the opportunity to

obtain real estate exposure without direct asset ownership and management Although REITs are often

1 httppcaobusorgStandardsAttestationPagesAT101aspxat_101_fn7 2 httppcaobusorgStandardsAttestationPagesAT701aspx

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 2

concentrated in one segment of the real estate industry many REITs are diversified through investment in multiple

property types

For tax purposes real estate companies in the US often prefer to be structured as REITs To be classified as a REIT

companies must maintain most of their assets in real estate derive most income from these assets and distribute a

minimum threshold of their annual taxable income to shareholders as dividends among other requirements Most

US-listed companies in the industry operate exclusively within the US while some companies have broadened

their real estate portfolio exposure internationally

Guidance for Disclosure of Sustainability Topics in SEC Filings

1 Industry-Level Sustainability Topics

For the Real Estate Owners Developers amp Investment Trusts industry SASB has identified the following

sustainability disclosure topics

bull Energy Management

bull Water Management

bull Management of Tenant Sustainability Impacts

bull Climate Change Adaptation

2 Company-Level Determination and Disclosure of Material Sustainability Topics

Sustainability disclosures are governed by the same laws and regulations that govern disclosures by securities issuers

generally According to the US Supreme Court a fact is material if in the event such fact is omitted from a

particular disclosure there is ldquoa substantial likelihood that the disclosure of the omitted fact would have been

viewed by the reasonable investor as having significantly altered the lsquototal mixrsquo of the information made

availablerdquo34

SASB has attempted to identify those sustainability topics that are reasonably likely to have a material effect on the

financial condition or operating performance of companies within each SICS industry SASB recognizes however

that each company is ultimately responsible for determining what information should be disclosed within the

context of Regulation S-K and other guidance

Regulation S-K which sets forth certain disclosure requirements associated with Form 10-K and other SEC filings

requires companies among other things to describe in the Managementrsquos Discussion and Analysis of Financial

Condition and Results of Operations (MDampA) section of Form 10-K ldquoany known trends or uncertainties that have

had or that the registrant reasonably expects will have a material favorable or unfavorable impact on net sales or

revenues or income from continuing operations If the registrant knows of events that will cause a material change

in the relationship between costs and revenues (such as known future increases in costs of labor or materials or price

increases or inventory adjustments) the change in the relationship shall be disclosedrdquo

3 TSC Industries v Northway Inc 426 US 438 (1976)4 CFR 229303(Item 303)(a)(3)(ii)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL ltFEFF0055007300740061007700690065006e0069006100200064006f002000740077006f0072007a0065006e0069006100200064006f006b0075006d0065006e007400f300770020005000440046002000700072007a0065007a006e00610063007a006f006e00790063006800200064006f002000770079006400720075006b00f30077002000770020007700790073006f006b00690065006a0020006a0061006b006f015b00630069002e002000200044006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d006900650020004100630072006f00620061007400200069002000410064006f00620065002000520065006100640065007200200035002e0030002000690020006e006f00770073007a0079006d002egt13 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 4: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 1

INTRODUCTION

Purpose amp Structure

This document contains the SASB Sustainability Accounting Standard (SASB Standard) for the Real Estate Owners

Developers amp Investment Trusts industry

SASB Sustainability Accounting Standards are comprised of (1) disclosure guidance and (2) accounting

standards on sustainability topics for use by US and foreign public companies in their annual filings (Form 10-

K or 20-F) with the US Securities and Exchange Commission (SEC) To the extent relevant SASB Standards may

also be applicable to other periodic mandatory filings with the SEC such as the Form 10-Q Form S-1 and Form

8-K

SASB Standards identify sustainability topics at an industry level which may constitute material informationmdash

depending on a companyrsquos specific operating contextmdashfor a company within that industry SASB Standards are

intended to provide guidance to company management which is ultimately responsible for determining which

information is material and should therefore be included in its Form 10-K or 20-F and other periodic SEC filings

SASB Standards provide companies with standardized sustainability metrics designed to communicate performance

on industry level sustainability topics When making disclosure on sustainability topics companies can use SASB

Standards to help ensure that disclosure is standardized and therefore decision-useful relevant comparable and

complete

SASB Standards are intended to constitute ldquosuitable criteriardquo as defined by AT 10123 - 321 and referenced in AT

7012 as having the following attributes

bull ObjectivitymdashCriteria should be free from bias

bull MeasurabilitymdashCriteria should permit reasonably consistent measurements qualitative or quantitative

of subject matter

bull CompletenessmdashCriteria should be sufficiently complete so that those relevant factors that would alter

a conclusion about subject matter are not omitted

bull RelevancemdashCriteria should be relevant to the subject matter

Industry Description

The Real Estate Owners Developers amp Investment Trusts industry (the ldquoReal Estate industryrdquo) is composed of

companies that own develop and generally operate income-producing real estate assets Companies in this

industry are commonly structured as real estate investment trusts (REITs) and operate in a wide range of segments

within the real estate industry including residential retail office health care industrial and hotel properties REITs

typically focus on the direct ownership of real estate assets thereby providing investors with the opportunity to

obtain real estate exposure without direct asset ownership and management Although REITs are often

1 httppcaobusorgStandardsAttestationPagesAT101aspxat_101_fn7 2 httppcaobusorgStandardsAttestationPagesAT701aspx

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 2

concentrated in one segment of the real estate industry many REITs are diversified through investment in multiple

property types

For tax purposes real estate companies in the US often prefer to be structured as REITs To be classified as a REIT

companies must maintain most of their assets in real estate derive most income from these assets and distribute a

minimum threshold of their annual taxable income to shareholders as dividends among other requirements Most

US-listed companies in the industry operate exclusively within the US while some companies have broadened

their real estate portfolio exposure internationally

Guidance for Disclosure of Sustainability Topics in SEC Filings

1 Industry-Level Sustainability Topics

For the Real Estate Owners Developers amp Investment Trusts industry SASB has identified the following

sustainability disclosure topics

bull Energy Management

bull Water Management

bull Management of Tenant Sustainability Impacts

bull Climate Change Adaptation

2 Company-Level Determination and Disclosure of Material Sustainability Topics

Sustainability disclosures are governed by the same laws and regulations that govern disclosures by securities issuers

generally According to the US Supreme Court a fact is material if in the event such fact is omitted from a

particular disclosure there is ldquoa substantial likelihood that the disclosure of the omitted fact would have been

viewed by the reasonable investor as having significantly altered the lsquototal mixrsquo of the information made

availablerdquo34

SASB has attempted to identify those sustainability topics that are reasonably likely to have a material effect on the

financial condition or operating performance of companies within each SICS industry SASB recognizes however

that each company is ultimately responsible for determining what information should be disclosed within the

context of Regulation S-K and other guidance

Regulation S-K which sets forth certain disclosure requirements associated with Form 10-K and other SEC filings

requires companies among other things to describe in the Managementrsquos Discussion and Analysis of Financial

Condition and Results of Operations (MDampA) section of Form 10-K ldquoany known trends or uncertainties that have

had or that the registrant reasonably expects will have a material favorable or unfavorable impact on net sales or

revenues or income from continuing operations If the registrant knows of events that will cause a material change

in the relationship between costs and revenues (such as known future increases in costs of labor or materials or price

increases or inventory adjustments) the change in the relationship shall be disclosedrdquo

3 TSC Industries v Northway Inc 426 US 438 (1976)4 CFR 229303(Item 303)(a)(3)(ii)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM ltFEFF005500740069006c0069007a00610163006900200061006300650073007400650020007300650074010300720069002000700065006e007400720075002000610020006300720065006100200064006f00630075006d0065006e00740065002000410064006f006200650020005000440046002000610064006500630076006100740065002000700065006e0074007200750020007400690070010300720069007200650061002000700072006500700072006500730073002000640065002000630061006c006900740061007400650020007300750070006500720069006f006100720103002e002000200044006f00630075006d0065006e00740065006c00650020005000440046002000630072006500610074006500200070006f00740020006600690020006400650073006300680069007300650020006300750020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e00300020015f00690020007600650072007300690075006e0069006c006500200075006c0074006500720069006f006100720065002egt13 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 5: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 2

concentrated in one segment of the real estate industry many REITs are diversified through investment in multiple

property types

For tax purposes real estate companies in the US often prefer to be structured as REITs To be classified as a REIT

companies must maintain most of their assets in real estate derive most income from these assets and distribute a

minimum threshold of their annual taxable income to shareholders as dividends among other requirements Most

US-listed companies in the industry operate exclusively within the US while some companies have broadened

their real estate portfolio exposure internationally

Guidance for Disclosure of Sustainability Topics in SEC Filings

1 Industry-Level Sustainability Topics

For the Real Estate Owners Developers amp Investment Trusts industry SASB has identified the following

sustainability disclosure topics

bull Energy Management

bull Water Management

bull Management of Tenant Sustainability Impacts

bull Climate Change Adaptation

2 Company-Level Determination and Disclosure of Material Sustainability Topics

Sustainability disclosures are governed by the same laws and regulations that govern disclosures by securities issuers

generally According to the US Supreme Court a fact is material if in the event such fact is omitted from a

particular disclosure there is ldquoa substantial likelihood that the disclosure of the omitted fact would have been

viewed by the reasonable investor as having significantly altered the lsquototal mixrsquo of the information made

availablerdquo34

SASB has attempted to identify those sustainability topics that are reasonably likely to have a material effect on the

financial condition or operating performance of companies within each SICS industry SASB recognizes however

that each company is ultimately responsible for determining what information should be disclosed within the

context of Regulation S-K and other guidance

Regulation S-K which sets forth certain disclosure requirements associated with Form 10-K and other SEC filings

requires companies among other things to describe in the Managementrsquos Discussion and Analysis of Financial

Condition and Results of Operations (MDampA) section of Form 10-K ldquoany known trends or uncertainties that have

had or that the registrant reasonably expects will have a material favorable or unfavorable impact on net sales or

revenues or income from continuing operations If the registrant knows of events that will cause a material change

in the relationship between costs and revenues (such as known future increases in costs of labor or materials or price

increases or inventory adjustments) the change in the relationship shall be disclosedrdquo

3 TSC Industries v Northway Inc 426 US 438 (1976)4 CFR 229303(Item 303)(a)(3)(ii)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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HEB 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL ltFEFF0055007300740061007700690065006e0069006100200064006f002000740077006f0072007a0065006e0069006100200064006f006b0075006d0065006e007400f300770020005000440046002000700072007a0065007a006e00610063007a006f006e00790063006800200064006f002000770079006400720075006b00f30077002000770020007700790073006f006b00690065006a0020006a0061006b006f015b00630069002e002000200044006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d006900650020004100630072006f00620061007400200069002000410064006f00620065002000520065006100640065007200200035002e0030002000690020006e006f00770073007a0079006d002egt13 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO ltFEFF004b00e40079007400e40020006e00e40069007400e4002000610073006500740075006b007300690061002c0020006b0075006e0020006c0075006f00740020006c00e400680069006e006e00e4002000760061006100740069007600610061006e0020007000610069006e006100740075006b00730065006e002000760061006c006d0069007300740065006c00750074007900f6006800f6006e00200073006f00700069007600690061002000410064006f0062006500200050004400460020002d0064006f006b0075006d0065006e007400740065006a0061002e0020004c0075006f0064007500740020005000440046002d0064006f006b0075006d0065006e00740069007400200076006f0069006400610061006e0020006100760061007400610020004100630072006f0062006100740069006c006c00610020006a0061002000410064006f00620065002000520065006100640065007200200035002e0030003a006c006c00610020006a006100200075007500640065006d006d0069006c006c0061002egt13 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 6: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 3

Furthermore Instructions to Item 303 state that the MDampA ldquoshall focus specifically on material events and

uncertainties known to management that would cause reported financial information not to be necessarily

indicative of future operating results or of future financial conditionrdquo2

The SEC has provided guidance for companies to use in determining whether a trend or uncertainty should be

disclosed The two-part assessment prescribed by the SEC based on probability and magnitude can be applied to

the topics included within this standard

bull First a company is not required to make disclosure about a known trend or uncertainty if its

management determines that such trend or uncertainty is not reasonably likely to occur

bull Second if a companyrsquos management cannot make a reasonable determination of the likelihood of an

event or uncertainty then disclosure is required unless management determines that a material effect

on the registrantrsquos financial condition or results of operation is not reasonably likely to occur

3 Sustainability Accounting Standard Disclosures in Form 10-K

a Managementrsquos Discussion and Analysis

For purposes of comparability and usability companies should consider making disclosure on

sustainability topics in the MDampA in a sub-section titled ldquoSustainability Accounting Standards

Disclosuresrdquo5

b Other Relevant Sections of Form 10-K

In addition to the MDampA section it may be relevant for companies to disclose sustainability information in

other sections of Form 10-K including but not limited to

bull Description of businessmdashItem 101 of Regulation S-K requires a company to provide a description of

its business and its subsidiaries Item 101(c)(1)(xii) expressly requires disclosure regarding certain costs

of complying with environmental laws

Appropriate disclosure also shall be made as to the material effects that compliance with Federal State and local

provisions which have been enacted or adopted regulating the discharge of materials into the environment or

otherwise relating to the protection of the environment may have upon the capital expenditures earnings and

competitive position of the registrant and its subsidiaries

bull Legal proceedingsmdashItem 103 of Regulation S-K requires companies to describe briefly any material

pending or contemplated legal proceedings Instructions to Item 103 provide specific disclosure

requirements for administrative or judicial proceedings arising from laws and regulations that target

discharge of materials into the environment or that are primarily for the purpose of protecting the

environment

5 SEC [Release Nos 33-8056 34-45321 FR-61] Commission Statement about Managementrsquos Discussion and Analysis of Financial Condition and Results of Operations ldquoWe also want to remind registrants that disclosure must be both useful and understandable That is management should provide the most relevant information and provide it using language and formats that investors can be expected to understand Registrants should be aware also that investors will often find information relating to a particular matter more meaningful if it is disclosed in a single location rather than presented in a fragmented manner throughout the filingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS 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 ESP 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HEB 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 LVI 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB ltFEFF005500740069006c0069007a006500200065007300730061007300200063006f006e00660069006700750072006100e700f50065007300200064006500200066006f0072006d00610020006100200063007200690061007200200064006f00630075006d0065006e0074006f0073002000410064006f0062006500200050004400460020006d00610069007300200061006400650071007500610064006f00730020007000610072006100200070007200e9002d0069006d0070007200650073007300f50065007300200064006500200061006c007400610020007100750061006c00690064006100640065002e0020004f007300200064006f00630075006d0065006e0074006f00730020005000440046002000630072006900610064006f007300200070006f00640065006d0020007300650072002000610062006500720074006f007300200063006f006d0020006f0020004100630072006f006200610074002000650020006f002000410064006f00620065002000520065006100640065007200200035002e0030002000650020007600650072007300f50065007300200070006f00730074006500720069006f007200650073002egt13 RUM 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 RUS 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 7: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 4

bull Risk factorsmdashItem 503(c) of Regulation S-K requires filing companies to provide a discussion of the

most significant factors that make an investment in the registrant speculative or risky clearly stating

the risk and specifying how a particular risk affects the particular filing company

c Rule 12b-20

Securities Act Rule 408 and Exchange Act Rule 12b-20 require a registrant to disclose in addition to the

information expressly required by law or regulation ldquosuch further material information if any as may be

necessary to make the required statements in light of the circumstances under which they are made not

misleadingrdquo

More detailed guidance on disclosure of material sustainability topics can be found in the SASB Conceptual

Framework available for download via httpwwwsasborgapproachconceptual-framework

Guidance on Accounting for Sustainability Topics

For each sustainability topic included in the Real Estate Owners Developers amp Investment Trusts Industry

Sustainability Accounting Standard SASB identifies accounting metrics

SASB recommends that each company consider using these sustainability accounting metrics when preparing

disclosures on the sustainability topics identified herein

As appropriatemdashand consistent with Rule 12b-206mdashwhen disclosing a sustainability topic identified by this

Standard companies should consider including a narrative description of any material factors necessary to ensure

completeness accuracy and comparability of the data reported Where not addressed by the specific accounting

metrics but relevant the registrant should discuss the following related to the topic

bull The registrantrsquos strategic approach to managing performance on material sustainability issues

bull The registrantrsquos relative performance with respect to its peers

bull The degree of control the registrant has

bull Any measures the registrant has undertaken or plans to undertake to improve performance

and

bull Data for the registrantrsquos last three completed fiscal years (when available)

SASB recommends that registrants use SASB Standards specific to their primary industry as identified in the

Sustainable Industry Classification System (SICStrade) If a registrant generates significant revenue from multiple

industries SASB recommends that it also consider sustainability topics that SASB has identified for those industries

and disclose the associated SASB accounting metrics

6 SEC Rule 12b-20 ldquoIn addition to the information expressly required to be included in a statement or report there shall be added such further material information if any as may be necessary to make the required statements in the light of the circumstances under which they are made not misleadingrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS 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 DAN 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HEB 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ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SUO 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 8: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 5

In disclosing to SASB Standards it is expected that registrants disclose with the same level of rigor accuracy and

responsibility as they apply to all other information contained in their SEC filings

Users of the SASB Standards

The SASB Standards are intended to provide guidance for companies that engage in public offerings of securities

registered under the Securities Act of 1933 (the Securities Act) and those that issue securities registered under the

Securities Exchange Act of 1934 (the Exchange Act)7 for use in SEC filings including without limitation annual

reports on Form 10-K (Form 20-F for foreign issuers) quarterly reports on Form 10-Q current reports on Form 8-K

and registration statements on Forms S-1 and S-3 Disclosure with respect to the SASB Standards is not required or

endorsed by the SEC or other entities governing financial reporting such as FASB GASB or IASB

Scope of Disclosure

Unless otherwise specified SASB recommends

bull That a registrant disclose on sustainability issues and metrics for itself and for entities that are

consolidated for financial reporting purposes as defined by accounting principles generally accepted in

the United States for consistency with other accompanying information within SEC filings8

bull That for consolidated entities disclosures be made and accounting metrics calculated for the whole

entity regardless of the size of the minority interest and

bull That information from unconsolidated entities not be included in the computation of SASB

accounting metrics A registrant should disclose however information about unconsolidated entities

to the extent that the registrant considers the information necessary for investors to understand the

effect of sustainability topics on the companyrsquos financial condition or operating performance

(typically this disclosure would be limited to risks and opportunities associated with these entities)

Reporting Format

Use of Financial Data

In instances where accounting metrics activity metrics and technical protocols in this standard incorporate

financial data (eg revenues cost of sales expenses recorded and disclosed for fines etc) such financial data shall

be prepared in accordance with the accounting principles generally accepted in the United States of America (ldquoUS

GAAPrdquo) and be consistent with the corresponding financial data reported within the registrantrsquos SEC filings Should

accounting metrics activity metrics and technical protocols in this standard incorporate disclosure of financial data

7 Registration under the Securities Exchange Act of 1934 is required (1) for securities to be listed on a national securities exchange such as the New York Stock Exchange the NYSE Amex and the NASDAQ Stock Market or (2) if (A) the securities are equity securities and are held by more than 2000 persons (or 500 persons who are not accredited investors) and (B) the company has more than $10 million in assets 8 See US GAAP consolidation rules (Section 810)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS 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ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200076006f006e002000640065006e0065006e002000530069006500200068006f006300680077006500720074006900670065002000500072006500700072006500730073002d0044007200750063006b0065002000650072007a0065007500670065006e0020006d00f60063006800740065006e002e002000450072007300740065006c006c007400650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000410064006f00620065002000520065006100640065007200200035002e00300020006f0064006500720020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP 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HEB 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB ltFEFF005500740069006c0069007a006500200065007300730061007300200063006f006e00660069006700750072006100e700f50065007300200064006500200066006f0072006d00610020006100200063007200690061007200200064006f00630075006d0065006e0074006f0073002000410064006f0062006500200050004400460020006d00610069007300200061006400650071007500610064006f00730020007000610072006100200070007200e9002d0069006d0070007200650073007300f50065007300200064006500200061006c007400610020007100750061006c00690064006100640065002e0020004f007300200064006f00630075006d0065006e0074006f00730020005000440046002000630072006900610064006f007300200070006f00640065006d0020007300650072002000610062006500720074006f007300200063006f006d0020006f0020004100630072006f006200610074002000650020006f002000410064006f00620065002000520065006100640065007200200035002e0030002000650020007600650072007300f50065007300200070006f00730074006500720069006f007200650073002egt13 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 9: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 6

that is not prepared in accordance with US GAAP the registrant shall disclose such information in accordance with

the SEC Regulation G

Activity Metrics and Normalization

SASB recognizes that normalizing accounting metrics is important for the analysis of SASB disclosures

SASB recommends that a registrant disclose any basic business data that may assist in the accurate evaluation and

comparability of disclosure to the extent that they are not already disclosed in the Form 10-K (eg revenue

EBITDA etc)

Such datamdashtermed ldquoactivity metricsrdquomdashmay include high-level business data such as total number of employees

quantity of products produced or services provided number of facilities or number of customers It may also

include industry-specific data such as plant capacity utilization (eg for specialty chemical companies) number of

transactions (eg for Internet media and services companies) hospital bed days (eg for health care delivery

companies) or proven and probable reserves (eg for oil and gas exploration and production companies)

Activity metrics disclosed should

bull Convey contextual information that would not otherwise be apparent from SASB accounting metrics

bull Be deemed generally useful for an investor relying on SASB accounting metrics in performing their

own calculations and creating their own ratios

bull Be explained and consistently disclosed from period to period to the extent they continue to be

relevant However a decision to make a voluntary disclosure in one period does not obligate a

continuation of that disclosure if it is no longer relevant or if a better metric becomes available9

9 Improving Business Reporting Insights into Enhancing Voluntary Disclosures FASB Business Reporting Research Project January 29 2001

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL ltFEFF0055007300740061007700690065006e0069006100200064006f002000740077006f0072007a0065006e0069006100200064006f006b0075006d0065006e007400f300770020005000440046002000700072007a0065007a006e00610063007a006f006e00790063006800200064006f002000770079006400720075006b00f30077002000770020007700790073006f006b00690065006a0020006a0061006b006f015b00630069002e002000200044006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d006900650020004100630072006f00620061007400200069002000410064006f00620065002000520065006100640065007200200035002e0030002000690020006e006f00770073007a0079006d002egt13 PTB 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 UKR 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 10: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 7

Where relevant SASB recommends specific activity metrics thatmdashat a minimummdashshould accompany SASB

accounting metric disclosures

ACTIVITY METRIC CATEGORY UNIT OF

MEASURE CODE

Number of assets by property subsector10 Quantitative Number IF0402-A

Leasable floor area by property subsector11 Quantitative Square feet (ft2) IF0402-B

Percentage of indirectly managed assets by property subsector12 Quantitative

Percentage () by floor area (ft2) IF0402-C

Average occupancy rate by property subsector13 Quantitative Percentage () IF0402-D

Units of Measure

Unless specified disclosures should be reported in International System of Units (SI units)

Uncertainty

SASB recognizes that there may be inherent uncertainty when disclosing certain sustainability data and information

This may be related to variables such as the reliance on data from third-party reporting systems and technologies

or the unpredictable nature of climate events Where uncertainty around a particular disclosure exists SASB

recommends that the registrant should consider discussing its nature and likelihood

Estimates

SASB recognizes that scientifically based estimates such as the reliance on certain conversion factors or the

exclusion of de minimis values may occur for certain quantitative disclosures Where appropriate SASB does not

discourage the use of such estimates When using an estimate for a particular disclosure SASB expects that the

registrant discuss its nature and substantiate its basis

10 Note to IF0402-AmdashNumber of assets shall include the number of distinct real estate property or building assets and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide Number of assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System The total number of assets reported across all subsectors can exceed the actual number of assets due to the fact that mixed-use assets can be reported in multiple subsectors11 Note to IF0402-BmdashLeasable floor area shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System Number of units may be used in place of floor area in the Apartments and LodgingResorts property subsectors when floor area is not available12 Note to IF0402-CmdashThe definition of ldquoindirectly managed assetsrdquo is solely based on the landlordtenant relationship and is aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoWhere a single tenant has the sole authority to introduce and implement operating andor environmental policies and measures the tenant should be assumed to have operational control so [the asset] should be considered to be an Indirectly Managed Assetrdquo Percentage of indirectly managed assets shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System13 Note to IF0402-DmdashAverage occupancy rate shall be disclosed separately for each portion of the registrantrsquos portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 BGR ltFEFF04180437043f043e043b043704320430043904420435002004420435043704380020043d0430044104420440043e0439043a0438002c00200437043000200434043000200441044a0437043404300432043004420435002000410064006f00620065002000500044004600200434043e043a0443043c0435043d04420438002c0020043c0430043a04410438043c0430043b043d043e0020043f044004380433043e04340435043d04380020043704300020043204380441043e043a043e043a0430044704350441044204320435043d0020043f04350447043004420020043704300020043f044004350434043f0435044704300442043d04300020043f043e04340433043e0442043e0432043a0430002e002000200421044a04370434043004340435043d043804420435002000500044004600200434043e043a0443043c0435043d044204380020043c043e0433043004420020043404300020044104350020043e0442043204300440044f0442002004410020004100630072006f00620061007400200438002000410064006f00620065002000520065006100640065007200200035002e00300020043800200441043b0435043404320430044904380020043204350440044104380438002egt13 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 11: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 8

Timing

Unless otherwise specified disclosure shall be for the registrantrsquos fiscal year

Limitations

There is no guarantee that SASB Standards address all sustainability impacts or opportunities associated with a

sector industry or company and therefore a company must determine for itself the topicsmdashsustainability-related

or otherwisemdashthat warrant discussion in its SEC filings

Disclosure under SASB Standards is voluntary It is not intended to replace any legal or regulatory requirements that

may be applicable to user operations Where such laws or regulations address legal or regulatory topics disclosure

under SASB Standards is not meant to supersede those requirements Disclosure according to SASB Standards shall

not be construed as demonstration of compliance with any law regulation or other requirement

SASB Standards are intended to be aligned with the principles of materiality enforced by the SEC However SASB is

not affiliated with or endorsed by the SEC or other entities governing financial reporting such as FASB GASB or

IASB

Forward-looking Statements

Disclosures on sustainability topics can involve discussion of future trends and uncertainties related to the

registrantrsquos operations and financial condition including those influenced by external variables (eg environmental

social regulatory and political) Companies making such disclosures should familiarize themselves with the safe

harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act which preclude civil

liability for material misstatements or omissions in such statements if the registrant takes certain steps including

among other things identifying the disclosure as ldquoforward-lookingrdquo and accompanying such disclosure with

ldquomeaningful cautionary statements identifying important factors that could cause actual results to differ materially

from those in the forward-looking statementsrdquo

The following sections contain the disclosure guidance associated with each accounting metric such as guidance on

definitions scope accounting compilation and presentation

The term ldquoshallrdquo is used throughout this document to indicate those elements that reflect requirements of the

Standard The terms ldquoshouldrdquo and ldquomayrdquo are used to indicate guidance which although not required provides a

recommended means of disclosure

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB ltFEFF05D405E905EA05DE05E905D5002005D105D405D205D305E805D505EA002005D005DC05D4002005DB05D305D9002005DC05D905E605D505E8002005DE05E105DE05DB05D9002000410064006F006200650020005000440046002005D405DE05D505EA05D005DE05D905DD002005DC05D405D305E405E105EA002005E705D305DD002D05D305E405D505E1002005D005D905DB05D505EA05D905EA002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002E05D005DE05D905DD002005DC002D005000440046002F0058002D0033002C002005E205D905D905E005D5002005D105DE05D305E805D905DA002005DC05DE05E905EA05DE05E9002005E905DC0020004100630072006F006200610074002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002Egt13 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA ltFEFF005500740069006c0069007a007a006100720065002000710075006500730074006500200069006d0070006f007300740061007a0069006f006e00690020007000650072002000630072006500610072006500200064006f00630075006d0065006e00740069002000410064006f00620065002000500044004600200070006900f900200061006400610074007400690020006100200075006e00610020007000720065007300740061006d0070006100200064006900200061006c007400610020007100750061006c0069007400e0002e0020004900200064006f00630075006d0065006e007400690020005000440046002000630072006500610074006900200070006f00730073006f006e006f0020006500730073006500720065002000610070006500720074006900200063006f006e0020004100630072006f00620061007400200065002000410064006f00620065002000520065006100640065007200200035002e003000200065002000760065007200730069006f006e006900200073007500630063006500730073006900760065002egt13 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS ltFEFF04180441043f043e043b044c04370443043904420435002004340430043d043d044b04350020043d0430044104420440043e0439043a043800200434043b044f00200441043e043704340430043d0438044f00200434043e043a0443043c0435043d0442043e0432002000410064006f006200650020005000440046002c0020043c0430043a04410438043c0430043b044c043d043e0020043f043e04340445043e0434044f04490438044500200434043b044f00200432044b0441043e043a043e043a0430044704350441044204320435043d043d043e0433043e00200434043e043f0435044704300442043d043e0433043e00200432044b0432043e04340430002e002000200421043e043704340430043d043d044b04350020005000440046002d0434043e043a0443043c0435043d0442044b0020043c043e0436043d043e0020043e0442043a0440044b043204300442044c002004410020043f043e043c043e0449044c044e0020004100630072006f00620061007400200438002000410064006f00620065002000520065006100640065007200200035002e00300020043800200431043e043b043504350020043f043e04370434043d043804450020043204350440044104380439002egt13 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 12: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 9

Table 1 Sustainability Disclosure Topics amp Accounting Metrics

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Energy Management

Energy consumption data coverage as a percentage of floor area by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-01

Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

Quantitative Gigajoules (GJ) Percentage ()

IF0402-02

Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

Quantitative Percentage () by gigajoules (GJ)

IF0402-03

Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg byproperty subsector

Quantitative Percentage () by floor area (ft2)

IF0402-04

Description of how building energy management considerations are integrated into property investment analysis and operational strategy

Discussion and Analysis

na IF0402-05

Water Management

Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-06

Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

Quantitative Cubic meters (m3) Percentage ()

IF0402-07

Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

Quantitative Percentage () by cubic meters (m3)

IF0402-08

Discussion of water management risks and description of strategies and practices to mitigate those risks

Discussion and Analysis na IF0402-09

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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ltFEFF04180437043f043e043b043704320430043904420435002004420435043704380020043d0430044104420440043e0439043a0438002c00200437043000200434043000200441044a0437043404300432043004420435002000410064006f00620065002000500044004600200434043e043a0443043c0435043d04420438002c0020043c0430043a04410438043c0430043b043d043e0020043f044004380433043e04340435043d04380020043704300020043204380441043e043a043e043a0430044704350441044204320435043d0020043f04350447043004420020043704300020043f044004350434043f0435044704300442043d04300020043f043e04340433043e0442043e0432043a0430002e002000200421044a04370434043004340435043d043804420435002000500044004600200434043e043a0443043c0435043d044204380020043c043e0433043004420020043404300020044104350020043e0442043204300440044f0442002004410020004100630072006f00620061007400200438002000410064006f00620065002000520065006100640065007200200035002e00300020043800200441043b0435043404320430044904380020043204350440044104380438002egt13 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP ltFEFF005500740069006c0069006300650020006500730074006100200063006f006e0066006900670075007200610063006900f3006e0020007000610072006100200063007200650061007200200064006f00630075006d0065006e0074006f00730020005000440046002000640065002000410064006f0062006500200061006400650063007500610064006f00730020007000610072006100200069006d0070007200650073006900f3006e0020007000720065002d0065006400690074006f007200690061006c00200064006500200061006c00740061002000630061006c0069006400610064002e002000530065002000700075006500640065006e00200061006200720069007200200064006f00630075006d0065006e0074006f00730020005000440046002000630072006500610064006f007300200063006f006e0020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e003000200079002000760065007200730069006f006e0065007300200070006f00730074006500720069006f007200650073002egt13 ETI 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 FRA 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 GRE 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HEB 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Page 13: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 10

Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)

TOPIC ACCOUNTING METRIC CATEGORY UNIT OF

MEASURE CODE

Management of Tenant Sustainability Impacts

Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

Quantitative

Percentage () by floor area (ft2) Square feet (ft2)

IF0402-10

Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

Quantitative Percentage () by floor area (ft2)

IF0402-11

Description of approach to measuring incentivizing and improving sustainability impacts of tenants

Discussion and Analysis na IF0402-12

Climate Change Adaptation

Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

Quantitative Square feet (ft2)

IF0402-13

Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

Discussion and Analysis na IF0402-14

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 RUM ltFEFF005500740069006c0069007a00610163006900200061006300650073007400650020007300650074010300720069002000700065006e007400720075002000610020006300720065006100200064006f00630075006d0065006e00740065002000410064006f006200650020005000440046002000610064006500630076006100740065002000700065006e0074007200750020007400690070010300720069007200650061002000700072006500700072006500730073002000640065002000630061006c006900740061007400650020007300750070006500720069006f006100720103002e002000200044006f00630075006d0065006e00740065006c00650020005000440046002000630072006500610074006500200070006f00740020006600690020006400650073006300680069007300650020006300750020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e00300020015f00690020007600650072007300690075006e0069006c006500200075006c0074006500720069006f006100720065002egt13 RUS 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 SVE 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 UKR 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 14: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 11

Energy Management

Description

Real estate assets consume significant amounts of energy primarily related to space heating ventilating air

conditioning water heating lighting and equipment and appliance use Type of energy used magnitude of

consumption and strategies for energy management are highly dependent on the real estate asset class among

other factors Generally grid electricity consumption is the predominant form of consumed energy though on-site

fuel combustion also serves an important role Energy costs may be borne by companies in the industry andor the

property occupants either way energy management is a significant industry issue To the extent that the real

estate owner assumes direct responsibility for energy costs such costs often represent significant operating costs

inherently indicating the importance of energy management Energy pricing volatility and a general trend of

electricity price increases energy-related regulations wide variations in energy performance across the existing

building stock and opportunities for efficiency improvements through economically attractive capital investments

all further point to the importance of energy management Energy costs assumed by occupants either in whole or

in part are nonetheless likely to significantly impact companies in the industry albeit through differing channels

Building energy performance is a notable driver of tenant demand as it allows them to control operating costs

mitigate the environmental impacts of operations and often just as importantly maintain a reputation for

resource conservation Additionally real estate owners may be exposed to energy-related regulations even when

energy costs are the responsibility of occupants Overall companies in the industry that effectively manage the

energy performance of their assets may see reduced operating costs and regulatory risks as well as increased

tenant demand rental rates and occupancy rates all of which drive revenue and asset value appreciation

Improving the energy performance of assets is highly dependent on property type and location target tenant

market local building codes physical and legal opportunities to deploy distributed renewable energy ability to

measure consumption and performance of existing building stock among other factors

Accounting Metrics

IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector

01 Energy consumption data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete energy consumption data coverage divided by the total portfolio gross floor

area for which energy is used where

bull Gross floor area is defined according to the US Environmental Protection Agency (EPA) ENERGY

STARreg definition as ldquothe total property square footage measured between the principal exterior

surfaces of the enclosing fixed walls of the building(s)rdquo

bull Floor area is considered to have complete energy consumption data coverage when energy

consumption data (ie energy types and amounts consumed) is obtained by the registrant for all

types of energy consumed in the relevant floor area during the fiscal year regardless of when such

data was obtained

If such data is not available for one or more types of energy consumed the relevant floor area

shall not be considered to have energy consumption data coverage

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE ltFEFF005400610074006f0020006e006100730074006100760065006e00ed00200070006f0075017e0069006a007400650020006b0020007600790074007600e101590065006e00ed00200064006f006b0075006d0065006e0074016f002000410064006f006200650020005000440046002c0020006b00740065007200e90020007300650020006e0065006a006c00e90070006500200068006f006400ed002000700072006f0020006b00760061006c00690074006e00ed0020007400690073006b00200061002000700072006500700072006500730073002e002000200056007900740076006f01590065006e00e900200064006f006b0075006d0065006e007400790020005000440046002000620075006400650020006d006f017e006e00e90020006f007400650076015900ed007400200076002000700072006f006700720061006d0065006300680020004100630072006f00620061007400200061002000410064006f00620065002000520065006100640065007200200035002e0030002000610020006e006f0076011b006a016100ed00630068002egt13 DAN 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 DEU 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 ESP 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 ETI 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f00620065002000500044004600200070006f0075007200200075006e00650020007100750061006c0069007400e90020006400270069006d007000720065007300730069006f006e00200070007200e9007000720065007300730065002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200035002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB ltFEFF05D405E905EA05DE05E905D5002005D105D405D205D305E805D505EA002005D005DC05D4002005DB05D305D9002005DC05D905E605D505E8002005DE05E105DE05DB05D9002000410064006F006200650020005000440046002005D405DE05D505EA05D005DE05D905DD002005DC05D405D305E405E105EA002005E705D305DD002D05D305E405D505E1002005D005D905DB05D505EA05D905EA002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002E05D005DE05D905DD002005DC002D005000440046002F0058002D0033002C002005E205D905D905E005D5002005D105DE05D305E805D905DA002005DC05DE05E905EA05DE05E9002005E905DC0020004100630072006F006200610074002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002Egt13 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 15: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 12

02 The scope of energy includes

bull Energy purchased from sources external to the registrant and its tenants or produced by the registrant

or its tenants themselves (self-generated)

bull Energy from all sources including direct fuel usage purchased electricity and heating cooling and

steam energy

03 The registrant may choose to discuss the comprehensiveness of data coverage if coverage variations by

energy type exist (eg if a portion of floor area consumes electricity and natural gas and the registrant has

energy consumption data coverage for electricity but not natural gas the registrant does not have

complete energy consumption data coverage but may choose to disclose the portion of total portfolio

gross floor area with partial energy consumption data coverage)

04 The registrant may choose to describe the variations in energy consumption data coverage including the

factors that influence it

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence energy consumption data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Administrative or logistical barriers to obtaining energy consumption data (eg lack of

integration of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of energy consumption data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

energy consumption data by the registrant and the ability of the registrant to influence energy

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space energy consumption data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 UKR 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 16: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 13

05 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

06 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete energy

consumption data coverage the leasable floor area may be added to the numerator and denominator for

the relevant building in the above calculation in place of gross floor area)

07 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

08 The registrant shall disclose energy consumption data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

09 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN 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 DEU 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 ESP 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 ETI 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f00620065002000500044004600200070006f0075007200200075006e00650020007100750061006c0069007400e90020006400270069006d007000720065007300730069006f006e00200070007200e9007000720065007300730065002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200035002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH ltFEFF004e006100750064006f006b0069007400650020016100690075006f007300200070006100720061006d006500740072007500730020006e006f0072011700640061006d00690020006b0075007200740069002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b00750072006900650020006c0061006200690061007500730069006100690020007000720069007400610069006b007900740069002000610075006b01610074006f00730020006b006f006b007900620117007300200070006100720065006e006700740069006e00690061006d00200073007000610075007300640069006e0069006d00750069002e0020002000530075006b0075007200740069002000500044004600200064006f006b0075006d0065006e007400610069002000670061006c006900200062016b007400690020006100740069006400610072006f006d00690020004100630072006f006200610074002000690072002000410064006f00620065002000520065006100640065007200200035002e0030002000610072002000760117006c00650073006e0117006d00690073002000760065007200730069006a006f006d00690073002egt13 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV ltFEFF005400650020006e006100730074006100760069007400760065002000750070006f0072006100620069007400650020007a00610020007500730074007600610072006a0061006e006a006500200064006f006b0075006d0065006e0074006f0076002000410064006f006200650020005000440046002c0020006b006900200073006f0020006e0061006a007000720069006d00650072006e0065006a016100690020007a00610020006b0061006b006f0076006f00730074006e006f0020007400690073006b0061006e006a00650020007300200070007200690070007200610076006f0020006e00610020007400690073006b002e00200020005500730074007600610072006a0065006e006500200064006f006b0075006d0065006e0074006500200050004400460020006a00650020006d006f0067006f010d00650020006f0064007000720065007400690020007a0020004100630072006f00620061007400200069006e002000410064006f00620065002000520065006100640065007200200035002e003000200069006e0020006e006f00760065006a01610069006d002egt13 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 17: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 14

IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector

10 The registrant shall disclose total energy consumption by the portfolio area for which there is energy

consumption data coverage as an aggregate figure in gigajoules or their multiples where

bull Energy consumption data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is energy

consumption data coverage regardless of whether energy is consumed by the Tenant Space or Base

Building (including outdoor exterior and parking areas) and which party pays for energy expenses

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable14

If energy consumption data is not available for Tenant Space or Whole Building for a property but

is available for the Base Building then the registrant shall disclose this energy consumption data

bull The scope of energy includes

Energy purchased from sources external to the registrant and its tenants or produced by the

registrant or its tenants themselves (self-generated)

Energy from all sources including direct fuel usage purchased electricity and heating cooling

and steam energy

11 In calculating energy consumption from fuels and biofuels the registrant shall use higher heating values

(HHV) also known as gross calorific values (GCV) which are directly measured or taken from the

Intergovernmental Panel on Climate Change (IPCC) the US Department of Energy (DOE) or the US

Energy Information Administration (EIA)

12 The registrant shall disclose grid electricity consumption as a percentage of total energy consumption

13 The registrant shall disclose renewable energy consumption as a percentage of total energy consumption

14 The scope of renewable energy includes renewable fuel the registrant and its tenants consume and

renewable energy the registrant and its tenants directly produce purchase through a renewable power

purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or for which Green-

e Energy Certified RECs are paired with grid electricity

bull For any renewable electricity generated on-site any RECs must be retained (ie not sold) and retired

on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

14 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-02 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM ltFEFF005500740069006c0069007a00610163006900200061006300650073007400650020007300650074010300720069002000700065006e007400720075002000610020006300720065006100200064006f00630075006d0065006e00740065002000410064006f006200650020005000440046002000610064006500630076006100740065002000700065006e0074007200750020007400690070010300720069007200650061002000700072006500700072006500730073002000640065002000630061006c006900740061007400650020007300750070006500720069006f006100720103002e002000200044006f00630075006d0065006e00740065006c00650020005000440046002000630072006500610074006500200070006f00740020006600690020006400650073006300680069007300650020006300750020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e00300020015f00690020007600650072007300690075006e0069006c006500200075006c0074006500720069006f006100720065002egt13 RUS 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 18: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 15

bull For renewable PPAs the agreement must explicitly include and convey that RECs be retained and

retired on behalf of the registrant or its tenants in order for the registrant to claim them as renewable

energy

bull The renewable portion of the electricity grid mix that is outside of the control or influence of the

registrant and its tenants is excluded from disclosure15

bull Renewable energy is defined as energy from sources that are replenished at a rate greater than or

equal to their rate of depletion consistent with US EPA definitions such as geothermal wind solar

hydro and biomass

15 For the purposes of this disclosure the scope of renewable energy from hydro and biomass sources is

limited to the following

bull Energy from hydro sources that are certified by the Low Impact Hydropower Institute or that are

eligible for a state Renewable Portfolio Standard

bull Energy from biomass sources is limited to materials certified to a third-party standard (eg Forest

Stewardship Council Sustainable Forest Initiative Programme for the Endorsement of Forest

Certification or American Tree Farm System) materials considered ldquoeligible renewablesrdquo according to

the Green-e Energy National Standard Version 25 (2014) and materials that are eligible for a state

Renewable Portfolio Standard

16 The registrant shall apply conversion factors consistently for all data reported under this disclosure such as

the use of HHVs for fuel usage (including biofuels) and conversion of kWh to gigajoules (for energy data

including electricity from solar or wind energy)

17 The registrant shall disclose total energy consumed separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

18 The registrant may choose to describe the variations in energy consumption

bull Variations in energy consumption data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

15 SASB recognizes that RECs reflect the environmental attributes of renewable energy that have been introduced to the grid

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 19: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 16

Managed assets and indirectly managed assets and

Geographical markets

19 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

20 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI ltFEFF0049007a006d0061006e0074006f006a00690065007400200161006f00730020006900650073007400610074012b006a0075006d00750073002c0020006c0061006900200076006500690064006f00740075002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006100730020006900720020012b00700061016100690020007000690065006d01130072006f00740069002000610075006700730074006100730020006b00760061006c0069007401010074006500730020007000690072006d007300690065007300700069006501610061006e006100730020006400720075006b00610069002e00200049007a0076006500690064006f006a006900650074002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006f002000760061007200200061007400760113007200740020006100720020004100630072006f00620061007400200075006e002000410064006f00620065002000520065006100640065007200200035002e0030002c0020006b0101002000610072012b00200074006f0020006a00610075006e0101006b0101006d002000760065007200730069006a0101006d002egt13 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 20: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 17

IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector

21 Like-for-like change in energy consumption shall be disclosed as a percentage and calculated as the total

energy consumption in the fiscal year divided by the total energy consumption in the immediately prior

fiscal year where

bull The scope of energy consumption included in calculation of ldquolike-for-like changerdquo shall be aligned

with that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all energy consumed by properties that were in the registrantrsquos portfolio

for both the full fiscal year and the immediately prior full fiscal year

Energy consumed by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of energy consumed by property area in the registrantrsquos portfolio for

which energy consumption data is unavailable for the full fiscal year andor the immediately prior full

fiscal year16

22 Like-for-like change in energy consumption shall be disclosed by (1)(a) Base Building and (b) Tenant Space

or (2) Whole Building or a combination of these

bull If like-for-like change in energy consumption data is not available for Tenant Space or Whole Building

for a property but is available for the Base Building then the registrant shall disclose this like-for-like

change in energy consumption data

23 The scope methodology and calculations of energy consumption shall be consistent with IF0402-02

24 The registrant shall disclose like-for-like change in energy consumption separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

25 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

energy consumption if the scope significantly diverges from the floor area of energy consumption data

coverage

16 SASB recognizes that there may be property area in the registrantrsquos portfolio for which energy consumption data coverage is unavailable in which case IF0402-03 will not reflect the entirety of energy consumption within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI ltFEFF0049007a006d0061006e0074006f006a00690065007400200161006f00730020006900650073007400610074012b006a0075006d00750073002c0020006c0061006900200076006500690064006f00740075002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006100730020006900720020012b00700061016100690020007000690065006d01130072006f00740069002000610075006700730074006100730020006b00760061006c0069007401010074006500730020007000690072006d007300690065007300700069006501610061006e006100730020006400720075006b00610069002e00200049007a0076006500690064006f006a006900650074002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b006f002000760061007200200061007400760113007200740020006100720020004100630072006f00620061007400200075006e002000410064006f00620065002000520065006100640065007200200035002e0030002c0020006b0101002000610072012b00200074006f0020006a00610075006e0101006b0101006d002000760065007200730069006a0101006d002egt13 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR ltFEFF005900fc006b00730065006b0020006b0061006c006900740065006c0069002000f6006e002000790061007a006401310072006d00610020006200610073006b013100730131006e006100200065006e0020006900790069002000750079006100620069006c006500630065006b002000410064006f006200650020005000440046002000620065006c00670065006c0065007200690020006f006c0075015f007400750072006d0061006b0020006900e70069006e00200062007500200061007900610072006c0061007201310020006b0075006c006c0061006e0131006e002e00200020004f006c0075015f0074007500720075006c0061006e0020005000440046002000620065006c00670065006c0065007200690020004100630072006f006200610074002000760065002000410064006f00620065002000520065006100640065007200200035002e003000200076006500200073006f006e0072006100730131006e00640061006b00690020007300fc007200fc006d006c00650072006c00650020006100e70131006c006100620069006c00690072002egt13 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 21: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 18

26 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in energy consumption For

example if additional assets are excluded from the like-for-like change in energy consumption relative

to like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

27 The registrant may choose to additionally present like-for-like change in energy consumption on a

normalized basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in energy

consumption the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology (eg ldquoWeather Normalized Energyrdquo as provided

by ENERGY STAR Portfolio Managerreg)

28 The registrant may choose to describe the variations in like-for-like change in energy consumption

bull Variations in energy consumption may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Energy purchased by the landlord and energy purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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JPEG2000ColorImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 AntiAliasGrayImages false13 CropGrayImages true13 GrayImageMinResolution 30013 GrayImageMinResolutionPolicy OK13 DownsampleGrayImages true13 GrayImageDownsampleType Bicubic13 GrayImageResolution 30013 GrayImageDepth -113 GrayImageMinDownsampleDepth 213 GrayImageDownsampleThreshold 15000013 EncodeGrayImages true13 GrayImageFilter DCTEncode13 AutoFilterGrayImages true13 GrayImageAutoFilterStrategy JPEG13 GrayACSImageDict ltlt13 QFactor 01513 HSamples [1 1 1 1] VSamples [1 1 1 1]13 gtgt13 GrayImageDict ltlt13 QFactor 01513 HSamples [1 1 1 1] VSamples [1 1 1 1]13 gtgt13 JPEG2000GrayACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 JPEG2000GrayImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 AntiAliasMonoImages false13 CropMonoImages true13 MonoImageMinResolution 120013 MonoImageMinResolutionPolicy OK13 DownsampleMonoImages true13 MonoImageDownsampleType Bicubic13 MonoImageResolution 120013 MonoImageDepth -113 MonoImageDownsampleThreshold 15000013 EncodeMonoImages true13 MonoImageFilter CCITTFaxEncode13 MonoImageDict ltlt13 K -113 gtgt13 AllowPSXObjects false13 CheckCompliance [13 None13 ]13 PDFX1aCheck false13 PDFX3Check false13 PDFXCompliantPDFOnly false13 PDFXNoTrimBoxError true13 PDFXTrimBoxToMediaBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXSetBleedBoxToMediaBox true13 PDFXBleedBoxToTrimBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXOutputIntentProfile ()13 PDFXOutputConditionIdentifier ()13 PDFXOutputCondition ()13 PDFXRegistryName ()13 PDFXTrapped False1313 CreateJDFFile false13 Description ltlt13 ARA 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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 UKR 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 22: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 19

29 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as ldquoEnergy consumed in supplying central building services to

lettableleasable areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as ldquoEnergy used by tenants and base building services to lettableleasable

and common spaces This should include all energy supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as ldquoEnergy purchased by the landlord but consumed by the tenant

This can include energy purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as ldquoEnergy purchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

30 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector

31 The registrant shall disclose the percentage of the portfolio that has a valid or current energy rating by

gross floor area where

bull The percentage shall be calculated as the total portfolio gross floor area that obtained an energy

rating divided by the total portfolio gross floor area

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 23: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 20

bull An energy rating is defined according to the 2016 GRESB Real Estate Assessment Reference Guide as

a scheme that measures the energy performance of buildings including schemes solely concerned

with measuring energy performance as well as cases in which an energy rating is an element of a

broader scheme measuring environmental performance

bull The scope of energy rating schemes includes

ENERGY STARreg for operations in the US and Canada

EU Energy Performance Certificates (EPC) for operations in the European Union

NABERS Energy for operations in Australia

NABERSNZ for operations in New Zealand

Other energy rating schemes that can be demonstrated to have substantially equivalent criteria

methodology and presentation of results as those schemes above

bull The scope of disclosure is aligned with the 2016 GRESB Real Estate Assessment Reference Guide in

that it ldquoonly include[s] energy ratings that were awarded before or during the reporting period (pre-

assessments or other unofficial forms of pre-certification are not valid) Some energy ratings are valid

for a limited period onlymdashthe rating should be effective and official during the reporting periodrdquo

32 The registrant may additionally disclose the percentage by energy rating scheme (ie by country)

33 The registrant shall disclose the percentage of the portfolio that is certified to ENERGY STARreg

bull The percentage shall be calculated as the total portfolio gross floor area that is certified to ENERGY

STARreg in the United States divided by the total portfolio gross floor area in the United States

If property is located in Canada the registrant may separately disclose the percentage of the

portfolio in Canada that is certified to ENERGY STARreg

bull For a property to qualify as certified to ENERGY STARreg the certification must be effective and official

during the reporting period (as aligned with the 2016 GRESB Real Estate Assessment Reference

Guide)

34 The registrant may exclude from the scope the property area that is ineligible to receive an energy rating or

certification based on the property subsector location (eg located in a region in which energy ratings are

not a commercially available service) or other specific use characteristics

35 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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JPEG2000ColorImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 AntiAliasGrayImages false13 CropGrayImages true13 GrayImageMinResolution 30013 GrayImageMinResolutionPolicy OK13 DownsampleGrayImages true13 GrayImageDownsampleType Bicubic13 GrayImageResolution 30013 GrayImageDepth -113 GrayImageMinDownsampleDepth 213 GrayImageDownsampleThreshold 15000013 EncodeGrayImages true13 GrayImageFilter DCTEncode13 AutoFilterGrayImages true13 GrayImageAutoFilterStrategy JPEG13 GrayACSImageDict ltlt13 QFactor 01513 HSamples [1 1 1 1] VSamples [1 1 1 1]13 gtgt13 GrayImageDict ltlt13 QFactor 01513 HSamples [1 1 1 1] VSamples [1 1 1 1]13 gtgt13 JPEG2000GrayACSImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 JPEG2000GrayImageDict ltlt13 TileWidth 25613 TileHeight 25613 Quality 3013 gtgt13 AntiAliasMonoImages false13 CropMonoImages true13 MonoImageMinResolution 120013 MonoImageMinResolutionPolicy OK13 DownsampleMonoImages true13 MonoImageDownsampleType Bicubic13 MonoImageResolution 120013 MonoImageDepth -113 MonoImageDownsampleThreshold 15000013 EncodeMonoImages true13 MonoImageFilter CCITTFaxEncode13 MonoImageDict ltlt13 K -113 gtgt13 AllowPSXObjects false13 CheckCompliance [13 None13 ]13 PDFX1aCheck false13 PDFX3Check false13 PDFXCompliantPDFOnly false13 PDFXNoTrimBoxError true13 PDFXTrimBoxToMediaBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXSetBleedBoxToMediaBox true13 PDFXBleedBoxToTrimBoxOffset [13 00000013 00000013 00000013 00000013 ]13 PDFXOutputIntentProfile ()13 PDFXOutputConditionIdentifier ()13 PDFXOutputCondition ()13 PDFXRegistryName ()13 PDFXTrapped False1313 CreateJDFFile false13 Description ltlt13 ARA 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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 UKR 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 24: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 21

IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy

36 The registrant shall describe its strategic approach and the operational processes it uses to integrate

energy-related considerations into its analysis of current and future property investments

37 The registrant shall discuss the following elements of its strategic approach where relevant

bull The use of energy-reduction targets and performance against those targets

bull The integration of property energy performance into its property acquisition due diligence process

such as if these measures are qualitative in nature (eg whether or not the building has an energy

performance certification) or quantitative in nature (eg the registrant adjusts occupancy rate

projections based on energy performance data) and

bull Entity-level energy consumption and management policies applicable across the registrantrsquos portfolio

(aligned with 2016 GRESB Real Estate Assessment Q8)

38 The registrant shall discuss the operational processes it uses which may include but are not limited to

bull Management of the technical energy performance of its portfolio and

bull The integration of renewable energy into its portfolio

39 Relevant elements of its technical approach may include but are not limited to

bull Use of technical building assessments to identify energy efficiency opportunities including whether

such assessments are in-house or external and the general portfolio coverage of such assessments

during the last three years (aligned with 2016 GRESB Real Estate Assessment Q16)

bull Measures implemented to improve the energy efficiency of the portfolio including specific measures

taken general portfolio coverage of such measures and estimated energy savings (aligned with 2016

GRESB Real Estate Assessment Q17)

bull Approach to retrocommissionings including their applicability to the registrantrsquos portfolio the

comprehensiveness of retrocommissionings conducted general portfolio coverage and estimated

energy savings

bull Use of environmental management systems to measure manage and improve the energy

performance of buildings and such systemsrsquo alignment with third-party standards or verification

(aligned with 2016 GRESB Real Estate Assessment Q21 ldquoEnvironmental Management Systemsrdquo) and

bull Use of data management systems to monitor analyze and benchmark energy performance of

individual buildings and such systemsrsquo alignment with third-party standards or verification (aligned

with 2016 GRESB Real Estate Assessment Q22 ldquoData Management Systemsrdquo)

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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ltFEFF06270633062A062E062F0645002006470630064700200627064406250639062F0627062F0627062A002006440625064606340627062100200648062B062706260642002000410064006F00620065002000500044004600200645062A064806270641064206290020064406440637062806270639062900200641064A00200627064406450637062706280639002006300627062A0020062F0631062C0627062A002006270644062C0648062F0629002006270644063906270644064A0629061B0020064A06450643064600200641062A062D00200648062B0627062606420020005000440046002006270644064506460634062306290020062806270633062A062E062F062706450020004100630072006F0062006100740020064800410064006F006200650020005200650061006400650072002006250635062F0627063100200035002E0030002006480627064406250635062F062706310627062A0020062706440623062D062F062B002E0635062F0627063100200035002E0030002006480627064406250635062F062706310627062A0020062706440623062D062F062B002Egt13 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM ltFEFF005500740069006c0069007a00610163006900200061006300650073007400650020007300650074010300720069002000700065006e007400720075002000610020006300720065006100200064006f00630075006d0065006e00740065002000410064006f006200650020005000440046002000610064006500630076006100740065002000700065006e0074007200750020007400690070010300720069007200650061002000700072006500700072006500730073002000640065002000630061006c006900740061007400650020007300750070006500720069006f006100720103002e002000200044006f00630075006d0065006e00740065006c00650020005000440046002000630072006500610074006500200070006f00740020006600690020006400650073006300680069007300650020006300750020004100630072006f006200610074002c002000410064006f00620065002000520065006100640065007200200035002e00300020015f00690020007600650072007300690075006e0069006c006500200075006c0074006500720069006f006100720065002egt13 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 25: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 22

40 The registrant shall discuss its strategies relating to energy ratings benchmarking and certifications

including their impact on tenant demand within the registrantrsquos target market(s) their relevance to the

property types in its portfolio such as the subsector(s) locations and construction (new versus existing

stock) and the costs and benefits associated with obtaining and maintaining an energy rating benchmark

and certification

bull If applicable the registrant shall discuss whether it prefers certifications that are based on ongoing

performance (eg ENERGY STARreg) or those based on performance-modeled design objectives

41 If the registrant participates in new construction or major renovations it shall discuss whether and how it

incorporates energy efficiency strategies into design and development

42 The registrant shall describe its approach to renewable energy generation which may include but not is

not limited to

bull The relevance of on-site and off-site renewable energy generation to the portfolio and energy

management strategy

bull Technical or legal limitations on the ability to incorporate renewable energy into the portfolio and

energy management strategy and

bull The energy generated from on-site and off-site renewable energy (aligned with 2016 GRESB Real

Estate Assessment Q253)

43 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL ltFEFF0055007300740061007700690065006e0069006100200064006f002000740077006f0072007a0065006e0069006100200064006f006b0075006d0065006e007400f300770020005000440046002000700072007a0065007a006e00610063007a006f006e00790063006800200064006f002000770079006400720075006b00f30077002000770020007700790073006f006b00690065006a0020006a0061006b006f015b00630069002e002000200044006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d006900650020004100630072006f00620061007400200069002000410064006f00620065002000520065006100640065007200200035002e0030002000690020006e006f00770073007a0079006d002egt13 PTB ltFEFF005500740069006c0069007a006500200065007300730061007300200063006f006e00660069006700750072006100e700f50065007300200064006500200066006f0072006d00610020006100200063007200690061007200200064006f00630075006d0065006e0074006f0073002000410064006f0062006500200050004400460020006d00610069007300200061006400650071007500610064006f00730020007000610072006100200070007200e9002d0069006d0070007200650073007300f50065007300200064006500200061006c007400610020007100750061006c00690064006100640065002e0020004f007300200064006f00630075006d0065006e0074006f00730020005000440046002000630072006900610064006f007300200070006f00640065006d0020007300650072002000610062006500720074006f007300200063006f006d0020006f0020004100630072006f006200610074002000650020006f002000410064006f00620065002000520065006100640065007200200035002e0030002000650020007600650072007300f50065007300200070006f00730074006500720069006f007200650073002egt13 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR ltFEFF005900fc006b00730065006b0020006b0061006c006900740065006c0069002000f6006e002000790061007a006401310072006d00610020006200610073006b013100730131006e006100200065006e0020006900790069002000750079006100620069006c006500630065006b002000410064006f006200650020005000440046002000620065006c00670065006c0065007200690020006f006c0075015f007400750072006d0061006b0020006900e70069006e00200062007500200061007900610072006c0061007201310020006b0075006c006c0061006e0131006e002e00200020004f006c0075015f0074007500720075006c0061006e0020005000440046002000620065006c00670065006c0065007200690020004100630072006f006200610074002000760065002000410064006f00620065002000520065006100640065007200200035002e003000200076006500200073006f006e0072006100730131006e00640061006b00690020007300fc007200fc006d006c00650072006c00650020006100e70131006c006100620069006c00690072002egt13 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 26: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 23

Water Management

Description

Buildings consume significant amounts of water in their operations through water fixtures building equipment

appliances and irrigation Operating costs resulting from water consumption may represent significant costs

depending on property type tenant operations geographical locations and other factors Companies in the

industry can be responsible for a buildingrsquos water costs or common area water costs though it is common to

allocate all or a portion of these costs to occupants In these arrangements water management continues to play

an important role through tenant demand and regulatory exposure Tenants may assess the water efficiency of real

estate assets in an effort to control operating costs mitigate environmental impacts of operations and often just

as importantly develop a reputation for resource conservation Additionally real estate owners may be exposed to

water-related regulations even when water costs are the responsibility of occupants Overall companies in the

industry that effectively manage water efficiency of assets even when they donrsquot face direct exposure to water

costs may see reduced operating costs and regulatory exposure as well as increased tenant demand rental rates

and occupancy rates all of which drive revenue and asset value appreciation Long-term historic increases in the

costs of water and expectations around continued increases due to overconsumption and constrained supplies

resulting from population growth and shifts pollution and climate change indicate the heightened importance of

water management The ability to improve asset water efficiency is highly dependent on the property type

locational water availability target tenant market local building codes the ability to measure consumption and

the level of current efficiency of existing building stock among other factors

Accounting Metrics

IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

44 Water withdrawal data coverage shall be disclosed as a percentage and calculated as the total portfolio

gross floor area with complete water withdrawal data coverage divided by the total portfolio gross floor

area for which water is used where

bull Gross floor area is defined according to the EPA ENERGY STARreg definition as ldquothe total property

square footage measured between the principal exterior surfaces of the enclosing fixed walls of the

building(s)rdquo

bull Floor area is considered to have complete water withdrawal data coverage when water withdrawal

data (ie amounts withdrawn) is obtained by the registrant in the relevant floor area during the fiscal

year regardless of when such data was obtained

45 The scope of water withdrawals is aligned with the 2016 GRESB Real Estate Assessment Reference Guide

and includes water that was withdrawn from all sources where

bull Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 27: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 24

46 The registrant shall disclose the percentage of water withdrawal data coverage in regions with High or

Extremely High Baseline Water Stress as classified by the World Resources Institutersquos (WRI) Water Risk Atlas

tool Aqueduct (publicly accessible online here)

bull The percentage shall be calculated as the total portfolio gross floor area with water withdrawal data

coverage in regions with High or Extremely High Baseline Water Stress divided by the total portfolio

gross floor area for which water is used in regions with High or Extremely High Baseline Water Stress

47 The registrant may choose to describe the variations in water withdrawal data coverage including the

factors that influence it

bull Variations in water withdrawal data coverage may occur based on distinctions including but not

limited to the following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

bull Relevant factors that influence water withdrawal data coverage may include but are not limited to

Geographical markets and the applicable enabling or inhibiting laws regulations and policies

within such markets including those policies of utilities

Geographical markets and the applicability of risks related to water scarcity (and related current

or future regulations)

Administrative or logistical barriers to obtaining water withdrawal data (eg lack of integration

of utilitiesrsquo data reporting systems)

Tenant demands around the privacy or proprietary nature of water withdrawal data

Property subsectors or other more nuanced classifications of property types

Lease structures including the length in time of leases the terms applicable to the access of

water withdrawal data by the registrant and the ability of the registrant to influence water

management performance of tenant spaces and

The registrantrsquos perception that its obtainment of tenant space water withdrawal data may

negatively impact tenant demand

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 28: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 25

48 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

49 Leasable floor area may be used in place of gross floor area when gross floor area is not available for the

relevant area of the portfolio (eg if a building with an unknown gross floor area has complete water

withdrawal data coverage the leasable floor area may be added to the numerator and denominator for the

relevant building in the above calculation in place of gross floor area)

50 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

51 The registrant shall disclose water withdrawal data coverage separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

52 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 ESP 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 UKR 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 29: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 26

IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector

53 The registrant shall disclose the total amount of water (in thousands of cubic meters) that was withdrawn

by the portfolio area for which there is water withdrawal data coverage where

bull Water withdrawal data shall be disclosed by (1)(a) Base Building and (b) Tenant Space or (2) Whole

Building or a combination of these

bull The scope includes all property area in the registrantrsquos portfolio for which there is water withdrawal

data coverage regardless of whether water is consumed by the Tenant Space or Base Building

(including outdoor exterior and parking areas) and which party pays for water expenses

bull The scope excludes the portion of water consumed by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable17

If water withdrawal data is not available for Tenant Space or Whole Building for a property but is

available for the Base Building then the registrant shall disclose this water withdrawal data

bull The scope of water withdrawal is aligned with the 2016 GRESB Real Estate Assessment Reference

Guide and includes water that was withdrawn from all sources where

Water sources include surface water (including water from wetlands rivers lakes and oceans)

groundwater rainwater collected directly and stored by the registrant wastewater obtained from

other entities municipal water supplies or supply from other water utilities

54 The registrant shall analyze all of its operations for water risks and identify activities that withdraw water in

locations with High (40ndash80) or Extremely High (gt80) Baseline Water Stress as classified by the WRIrsquos

Water Risk Atlas tool Aqueduct (publicly accessible online here)

55 The registrant shall disclose its water withdrawn in locations with High or Extremely High Baseline Water

Stress as a percentage of the total water withdrawn

56 The registrant shall disclose total water withdrawn separately for each portion of its portfolio where

properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System and

include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property sub

sector classifications)

17 SASB recognizes that there may be property area in the registrantrsquos portfolio for which water withdrawal data coverage is unavailable in which case IF0402-07 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN ltFEFF004b0069007600e1006c00f30020006d0069006e0151007300e9006701710020006e0079006f006d00640061006900200065006c0151006b00e90073007a00ed007401510020006e0079006f006d00740061007400e100730068006f007a0020006c006500670069006e006b00e1006200620020006d0065006700660065006c0065006c0151002000410064006f00620065002000500044004600200064006f006b0075006d0065006e00740075006d006f006b0061007400200065007a0065006b006b0065006c0020006100200062006500e1006c006c00ed007400e10073006f006b006b0061006c0020006b00e90073007a00ed0074006800650074002e0020002000410020006c00e90074007200650068006f007a006f00740074002000500044004600200064006f006b0075006d0065006e00740075006d006f006b00200061007a0020004100630072006f006200610074002000e9007300200061007a002000410064006f00620065002000520065006100640065007200200035002e0030002c0020007600610067007900200061007a002000610074007400f3006c0020006b00e9007301510062006200690020007600650072007a006900f3006b006b0061006c0020006e00790069007400680061007400f3006b0020006d00650067002egt13 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR ltFEFF004200720075006b00200064006900730073006500200069006e006e007300740069006c006c0069006e00670065006e0065002000740069006c002000e50020006f0070007000720065007400740065002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e00740065007200200073006f006d00200065007200200062006500730074002000650067006e0065007400200066006f00720020006600f80072007400720079006b006b0073007500740073006b00720069006600740020006100760020006800f800790020006b00760061006c0069007400650074002e0020005000440046002d0064006f006b0075006d0065006e00740065006e00650020006b0061006e002000e50070006e00650073002000690020004100630072006f00620061007400200065006c006c00650072002000410064006f00620065002000520065006100640065007200200035002e003000200065006c006c00650072002000730065006e006500720065002egt13 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE ltFEFF0041006e007600e4006e00640020006400650020006800e4007200200069006e0073007400e4006c006c006e0069006e006700610072006e00610020006f006d002000640075002000760069006c006c00200073006b006100700061002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e007400200073006f006d002000e400720020006c00e4006d0070006c0069006700610020006600f60072002000700072006500700072006500730073002d007500740073006b00720069006600740020006d006500640020006800f600670020006b00760061006c0069007400650074002e002000200053006b006100700061006400650020005000440046002d0064006f006b0075006d0065006e00740020006b0061006e002000f600700070006e00610073002000690020004100630072006f0062006100740020006f00630068002000410064006f00620065002000520065006100640065007200200035002e00300020006f00630068002000730065006e006100720065002egt13 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 30: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 27

57 The registrant may choose to describe the variations in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

58 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as ldquoThis definition of Managed assets

and the definition of Indirectly Managed assets are solely based on the landlordtenant relationship

Assets or buildings for which the landlord is determined to have operational control where

operational control is defined as having the ability to introduce and implement operating andor

environmental policies and measures In case both the landlord and tenant have the authority to

introduce and implement any or all of the policies mentioned above the asset or building should be

reported as a Managed asset Where a single tenant has the sole authority to introduce and

implement operating andor environmental policies and measures the tenant should be assumed to

have operational control so it should be considered to be an Indirectly Managed assetrdquo

59 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 31: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 28

IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector

60 Like-for-like change in water withdrawals shall be disclosed as a percentage and calculated as the total

water withdrawals in the fiscal year divided by the total water withdrawals in the immediately prior fiscal

year where

bull The scope of water withdrawn included in calculation of ldquolike-for-like changerdquo shall be aligned with

that outlined in the 2016 GRESB Real Estate Assessment Reference Guide (ldquoLike-for-like

Comparisonrdquo) as including all water withdrawn by properties that were in the registrantrsquos portfolio for

both the full fiscal year and the immediately prior full fiscal year

Water withdrawn by properties that have been acquired disposed of under development or

have undergone a major renovation during the fiscal year or the immediately prior fiscal year shall

be excluded

No correction for changes in the occupancy rate is needed and buildings with a high variation in

vacancy rates should be included

bull The scope excludes the portion of water withdrawn by property area in the registrantrsquos portfolio for

which water withdrawal data is unavailable for the full fiscal year andor the immediately prior full

fiscal year18

61 Like-for-like change in water withdrawals shall be disclosed by (1)(a) Base Building and (b) Tenant Space or

(2) Whole Building or a combination of these

bull If like-for-like change in water withdrawal data is not available for Tenant Space or Whole Building for

a property but is available for the Base Building then the registrant shall disclose this like-for-like

water withdrawal data

62 The scope methodology and calculations of water withdrawals shall be consistent with IF0402-07

63 The registrant shall disclose like-for-like change in water withdrawn separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

64 The registrant should disclose the floor area in square feet included in the scope of like-for-like change in

water withdrawals if the scope significantly diverges from the floor area of water withdrawal data

coverage

18 SASB recognizes that there may be property area in the registrantrsquos portfolio where water withdrawal data coverage is unavailable in which case IF0402-08 will not reflect the entirety of water withdrawals within the portfolio

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f00620065002000500044004600200070006f0075007200200075006e00650020007100750061006c0069007400e90020006400270069006d007000720065007300730069006f006e00200070007200e9007000720065007300730065002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200035002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE ltFEFF0041006e007600e4006e00640020006400650020006800e4007200200069006e0073007400e4006c006c006e0069006e006700610072006e00610020006f006d002000640075002000760069006c006c00200073006b006100700061002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e007400200073006f006d002000e400720020006c00e4006d0070006c0069006700610020006600f60072002000700072006500700072006500730073002d007500740073006b00720069006600740020006d006500640020006800f600670020006b00760061006c0069007400650074002e002000200053006b006100700061006400650020005000440046002d0064006f006b0075006d0065006e00740020006b0061006e002000f600700070006e00610073002000690020004100630072006f0062006100740020006f00630068002000410064006f00620065002000520065006100640065007200200035002e00300020006f00630068002000730065006e006100720065002egt13 TUR ltFEFF005900fc006b00730065006b0020006b0061006c006900740065006c0069002000f6006e002000790061007a006401310072006d00610020006200610073006b013100730131006e006100200065006e0020006900790069002000750079006100620069006c006500630065006b002000410064006f006200650020005000440046002000620065006c00670065006c0065007200690020006f006c0075015f007400750072006d0061006b0020006900e70069006e00200062007500200061007900610072006c0061007201310020006b0075006c006c0061006e0131006e002e00200020004f006c0075015f0074007500720075006c0061006e0020005000440046002000620065006c00670065006c0065007200690020004100630072006f006200610074002000760065002000410064006f00620065002000520065006100640065007200200035002e003000200076006500200073006f006e0072006100730131006e00640061006b00690020007300fc007200fc006d006c00650072006c00650020006100e70131006c006100620069006c00690072002egt13 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 32: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 29

65 ldquoLike-for-likerdquo data collection analysis and disclosure may be consistent with the approach with which the

registrant discloses its financial reporting data

bull If the registrant discloses its financial reporting data using a concept and methodology similar to

ldquoLike-for-Like Comparisonrdquo the registrant shall describe divergences between the scope of assets

andor floor area used in its financial reporting and its like-for-like change in water withdrawn For

example if additional assets are excluded from the like-for-like change in water withdrawn relative to

like-for-like financial reporting as a result of data coverage limitations such inconsistencies shall be

described

66 The registrant may choose to additionally present like-for-like change in water withdrawals on a normalized

basis

bull Normalization factors and methodologies may include but are not limited to the following which are

presented in the 2016 GRESB Real Estate Assessment Reference Guide

Occupancy rate

Footfall

Operational hours

Weather conditions

Degree days

Air conditioning andor natural ventilation

Building age andor

Other

bull If the registrant chooses to additionally disclose normalized ldquolike-for-likerdquo change in water

withdrawn the registrant shall provide a brief description of the normalization factor and

methodology or its use of a third-party methodology

67 The registrant may choose to describe the variations in like-for-like change in water withdrawn

bull Variations in water withdrawn may occur based on distinctions including but not limited to the

following

Base Building Tenant Space and Whole Building

Water purchased by the landlord and water purchased by tenants

Managed assets and indirectly managed assets and

Geographical markets

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 BGR 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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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Page 33: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 30

68 The following terms are defined according to the 2016 GRESB Real Estate Assessment Reference Guide

bull Base Building is defined as water ldquoconsumed in supplying central building services to lettableleasable

areas and common areasrdquo

bull Tenant Space is defined as ldquoLettable floor area (both vacant and letleased areas)rdquo

bull Whole Building is defined as water ldquoused by tenants and base building services to lettableleasable

and common spaces This should include all [water] supplied to the building for the operation of the

building and the tenant spacerdquo

bull Purchased by Landlord is defined as water ldquopurchased by the landlord but consumed by the tenant

This can include [water] purchased by the landlord but used for vacant spacerdquo

bull Purchased by Tenant is defined as water ldquopurchased by the tenant Typically this is data that is not

within the participants immediate controlhelliprdquo

bull Managed Assets and Indirectly Managed Assets are defined as follows ldquoThis definition of Managed

assets and the definition of Indirectly Managed assets are solely based on the landlordtenant

relationship [Managed and Indirectly Managed Assets are] assets or buildings for which the landlord

is determined to have operational control where operational control is defined as having the ability

to introduce and implement operating andor environmental policies and measures In case both the

landlord and tenant have the authority to introduce and implement any or all of the policies

mentioned above the asset or building should be reported as a Managed asset Where a single

tenant has the sole authority to introduce and implement operating andor environmental policies and

measures the tenant should be assumed to have operational control so it should be considered to be

an Indirectly Managed assetrdquo

69 The registrant shall consider the 2016 GRESB Real Estate Assessment Reference Guide as a normative

reference thus any updates made year-on-year shall be considered updates to this guidance

IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks

70 The registrant shall discuss its risks associated with water withdrawals

71 The registrant shall discuss where applicable risks to the availability of adequate clean water resources

bull Relevant information to provide may include but is not limited to

Environmental constraints such as operating in water-stressed regions drought interannual or

seasonal variability and risks due to the impact of climate change

External constraints such as volatility in water costs stakeholder perceptions and concerns

related to water withdrawals (eg those from local communities non-governmental

organizations and regulatory agencies) direct competition with and impact from the actions of

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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Page 34: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 31

other users (commercial and municipal) restrictions to withdrawals due to regulations and the

ability to obtain and retain water rights or permits

How risks may vary by withdrawal source including wetlands rivers lakes oceans groundwater

rainwater municipal water supplies or supply from other water utilities

72 The registrant should include a discussion of the potential impacts that these risks may have on its

operations and the timeline over which such risks are expected to manifest

bull Impacts may include but are not limited to those associated with costs revenues liabilities

continuity of operations and reputation

73 The registrant shall provide a description of its short-term and long-term strategy or plan to manage these

risks including the following where relevant

bull Any water management targets it has set and an analysis of performance against those targets

Water management targets can include water management goals that the registrant prioritizes to

manage its risks and opportunities associated with water withdrawals consumption or

discharge

Targets can include but are not limited to those associated with reducing water withdrawals

reducing water consumption reducing water discharges and improving water discharge quality

bull The scope of its strategy plans or targets such as whether they pertain differently to different

business units geographies or water-consuming operational processes

bull The activities and investments required to achieve the plans and targets and any risks or limiting

factors that might affect achievement of the plans andor targets

74 For water management targets the registrant shall additionally disclose

bull The percentage reduction or improvements from the base year where

The base year is the first year against which water management targets are evaluated toward the

achievement of the target

bull Whether the target is absolute or intensity based and the metric denominator if it is an intensity-

based target

bull The timelines for the water management plans including the start year the target year and the base

year

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 35: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 32

bull The mechanism(s) for achieving the target including

Efficiency efforts such as the use of water recycling closed-loop systems andor efficiency-driven

equipment and appliance upgrades

The planning and design for the water requirements of outdoor areas and irrigation

The use of tools and technologies (eg the World Wildlife Fund Water Risk Filter WRIWBCSD

Global Water Tool and Water Footprint Network Footprint Assessment Tool) to analyze water

use risk and opportunities and

Collaborations or programs in place with the community or other organizations

75 Disclosure of strategies plans and targets shall be limited to activities that were ongoing (active) or

reached completion during the fiscal year

76 The registrant may choose to discuss if its water management decisions and practices incorporate

consideration of any additional lifecycle impacts or environmental tradeoffs for the registrant including

tradeoffs associated with land-use impacts energy consumption and greenhouse gas (GHG) emissions

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU ltFEFF00560065007200770065006e00640065006e0020005300690065002000640069006500730065002000450069006e007300740065006c006c0075006e00670065006e0020007a0075006d002000450072007300740065006c006c0065006e00200076006f006e002000410064006f006200650020005000440046002d0044006f006b0075006d0065006e00740065006e002c00200076006f006e002000640065006e0065006e002000530069006500200068006f006300680077006500720074006900670065002000500072006500700072006500730073002d0044007200750063006b0065002000650072007a0065007500670065006e0020006d00f60063006800740065006e002e002000450072007300740065006c006c007400650020005000440046002d0044006f006b0075006d0065006e007400650020006b00f6006e006e0065006e0020006d006900740020004100630072006f00620061007400200075006e0064002000410064006f00620065002000520065006100640065007200200035002e00300020006f0064006500720020006800f600680065007200200067006500f600660066006e00650074002000770065007200640065006e002egt13 ESP 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 ETI 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR ltFEFF04120438043a043e0440043804410442043e043204430439044204350020044604560020043f043004400430043c043504420440043800200434043b044f0020044104420432043e04400435043d043d044f00200434043e043a0443043c0435043d044204560432002000410064006f006200650020005000440046002c0020044f043a04560020043d04300439043a04400430044904350020043f045604340445043e0434044f0442044c00200434043b044f0020043204380441043e043a043e044f043a04560441043d043e0433043e0020043f0435044004350434043404400443043a043e0432043e0433043e0020043404400443043a0443002e00200020042104420432043e04400435043d045600200434043e043a0443043c0435043d0442043800200050004400460020043c043e0436043d04300020043204560434043a0440043804420438002004430020004100630072006f006200610074002004420430002000410064006f00620065002000520065006100640065007200200035002e0030002004300431043e0020043f04560437043d04560448043e04570020043204350440044104560457002egt13 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

Page 36: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 33

Management of Tenant Sustainability Impacts

Description

Real estate assets generate significant sustainability impacts including resource consumptionmdashnamely energy and

watermdashwaste generation and impacts on occupant health through indoor environmental quality While companies

in the industry own real estate assets it is the tenant operations of such assets that is a dominant driver of

sustainability impacts produced by the built environment Tenants may design and construct leased spaces

according to their operating needs In turn their operations consume significant amounts of energy and water

generate waste and impact the health of those living working shopping or visiting the properties While these

sustainability impacts are often generated by tenant operations and activities real estate owners have an important

role in influencing tenant sustainability impacts The manner in which companies in the industry structure their

agreements contracts and relationships with tenants is instrumental in effectively managing the sustainability

impacts of their tenants and ultimately the impacts of their assets Managing tenant sustainability impacts may

include mitigating the problem of split incentives by aligning both partiesrsquo financial interests and sustainability

outcomes establishing systematic measurement and communication of resource consumption data creating

shared performance goals and mandating minimum sustainability performance or design requirements among

other strategies Effective management of tenant sustainability impacts particularly related to energy water and

indoor environmental quality may drive asset value appreciation increase tenant demand and satisfaction

decrease direct operating costs andor decrease risks related to building codes and regulations

Accounting Metrics

IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector

77 The percentage shall be calculated as the total portfolio newly leased floor area associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements divided by total portfolio

newly leased floor area where

bull A cost recovery clause for resource efficiency-related capital improvements is defined as a clause in a

lease agreement that allows the registrant to invest in capital improvements to the energy efficiency

andor water efficiency of properties while recovering all or a proportion of associated expenditures

from tenants regardless of the mechanism of cost recovery19 20

19 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the Green Lease Leaders application ldquoTenant cost recovery clause that can be used for energy efficiency-related capital improvements This typically means that the list of operating expenses is expanded to include capital expenses intended to save energy with the annual pass-through amount most often determined either by an amortization schedule or projected savingsrdquo 20 The definition of cost recovery clause for resource efficiency-related capital improvements is generally aligned with the 2016 GRESB Real Estate Assessment Reference Guide ldquoCost recovery clause for energy efficiency-related capital improvements Allows the landlord to implement energy-efficiency measures during the lease and to recover a proportion or all of those costs from the tenantrdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 CHS ltFEFF4f7f75288fd94e9b8bbe5b9a521b5efa7684002000410064006f006200650020005000440046002065876863900275284e8e9ad88d2891cf76845370524d53705237300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c676562535f00521b5efa768400200050004400460020658768633002gt13 CHT ltFEFF4f7f752890194e9b8a2d7f6e5efa7acb7684002000410064006f006200650020005000440046002065874ef69069752865bc9ad854c18cea76845370524d5370523786557406300260a853ef4ee54f7f75280020004100630072006f0062006100740020548c002000410064006f00620065002000520065006100640065007200200035002e003000204ee553ca66f49ad87248672c4f86958b555f5df25efa7acb76840020005000440046002065874ef63002gt13 CZE 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 DAN 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 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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Page 37: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 34

78 The scope of disclosure includes all of the properties in the registrantrsquos portfolio that were newly leased

during any part of the fiscal year and for which the associated lease was executed between the registrant

and the tenant

bull If the registrant executed lease amendments or letter agreements during the fiscal year that contain a

cost recovery clause for resource efficiency-related capital improvements the associated leased floor

area shall be included within the scope of disclosure and shall be added to the numerator and

denominator

79 The registrant shall disclose the total portfolio newly leased floor area that is associated with leases that

contain a cost recovery clause for resource efficiency-related capital improvements in square feet

80 The registrant shall disclose the percentage of new leases that contain a cost recovery clause for resource

efficiency-related capital improvements and the associated leased floor area separately for each portion of

its portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT

Classification System and include the following Health Care Self Storage Industrial Office Apartments

Manufactured Homes Single Family Homes Shopping Centers Regional Malls Free Standing

LodgingResorts Specialty Data Centers and Other (any other property type(s) that cannot be classified to

any of the previous property subsector classifications)

81 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

82 The registrant should provide a brief description of instances when such cost recovery clauses were

exercised including the extent throughout the portfolio and the financial implications

83 The registrant should describe whether its standard lease contracts include a cost recovery clause for

resource efficiency-related capital improvements (aligned with 2016 GRESB Real Estate Assessment Q39)

84 The registrant may choose to additionally disclose the percentage of all leases in effect as of the last day of

the fiscal year that contain a cost recovery clause for resource efficiency-related capital improvements

calculated in a manner consistent with the above percentage

85 The registrant may choose to additionally disclose the amount (in US dollars) of actual capital expenditures

associated with resource efficiency-related capital improvements that were recovered from tenants during

the fiscal year through the use of cost recovery clauses in leases

86 The registrant shall consider the 2016 GRESB Real Estate Assessment and the 2016 GRESB Real Estate

Assessment Reference Guide as normative references thus any updates made year-on-year shall be

considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DEU 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 ESP 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 ETI 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f00620065002000500044004600200070006f0075007200200075006e00650020007100750061006c0069007400e90020006400270069006d007000720065007300730069006f006e00200070007200e9007000720065007300730065002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200035002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH ltFEFF004e006100750064006f006b0069007400650020016100690075006f007300200070006100720061006d006500740072007500730020006e006f0072011700640061006d00690020006b0075007200740069002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b00750072006900650020006c0061006200690061007500730069006100690020007000720069007400610069006b007900740069002000610075006b01610074006f00730020006b006f006b007900620117007300200070006100720065006e006700740069006e00690061006d00200073007000610075007300640069006e0069006d00750069002e0020002000530075006b0075007200740069002000500044004600200064006f006b0075006d0065006e007400610069002000670061006c006900200062016b007400690020006100740069006400610072006f006d00690020004100630072006f006200610074002000690072002000410064006f00620065002000520065006100640065007200200035002e0030002000610072002000760117006c00650073006e0117006d00690073002000760065007200730069006a006f006d00690073002egt13 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS ltFEFF04180441043f043e043b044c04370443043904420435002004340430043d043d044b04350020043d0430044104420440043e0439043a043800200434043b044f00200441043e043704340430043d0438044f00200434043e043a0443043c0435043d0442043e0432002000410064006f006200650020005000440046002c0020043c0430043a04410438043c0430043b044c043d043e0020043f043e04340445043e0434044f04490438044500200434043b044f00200432044b0441043e043a043e043a0430044704350441044204320435043d043d043e0433043e00200434043e043f0435044704300442043d043e0433043e00200432044b0432043e04340430002e002000200421043e043704340430043d043d044b04350020005000440046002d0434043e043a0443043c0435043d0442044b0020043c043e0436043d043e0020043e0442043a0440044b043204300442044c002004410020043f043e043c043e0449044c044e0020004100630072006f00620061007400200438002000410064006f00620065002000520065006100640065007200200035002e00300020043800200431043e043b043504350020043f043e04370434043d043804450020043204350440044104380439002egt13 SKY 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 SLV 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 SUO 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Page 38: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 35

IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector

87 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

grid electricity usage resulting from their exclusive electricity consumption

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for their exclusive grid electricity consumption divided by the total portfolio

leasable floor area

88 The registrant shall disclose the percentage of tenants that are separately metered or submetered for the

water usage resulting from their exclusive water withdrawals

bull The percentage shall be calculated as the total leasable floor area leased to tenants that are separately

metered or submetered for the water usage resulting from their exclusive withdrawals divided by the

total portfolio leasable floor area

89 The registrant shall disclose the percentage of tenants that are separately metered or submetered for their

exclusive grid electricity consumption and water withdrawals separately for each portion of its portfolio

where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification System

and include the following Health Care Self Storage Industrial Office Apartments Manufactured Homes

Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty Data

Centers and Other (any other property type(s) that cannot be classified to any of the previous property

subsector classifications)

90 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants

91 The registrant shall describe its strategy and process for integrating considerations of sustainability into its

leases and tenant relationships (eg tenant communication voluntary initiatives selection of a third-party

property manager if applicable etc) in order to measure incentivize and improve impacts

92 For the purposes of this disclosure the scope of sustainability topics includes the following energy

management water management and the impacts of properties on tenant health including indoor

environmental quality

93 Relevant strategies to discuss include but are not limited to

bull The following components of the 2016 GRESB Real Estate Assessment Q391

Whether the registrant has agreements with its tenants to mutually share energy consumption

andor water withdrawal data

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN ltFEFF004200720075006700200069006e0064007300740069006c006c0069006e006700650072006e0065002000740069006c0020006100740020006f007000720065007400740065002000410064006f006200650020005000440046002d0064006f006b0075006d0065006e007400650072002c0020006400650072002000620065006400730074002000650067006e006500720020007300690067002000740069006c002000700072006500700072006500730073002d007500640073006b007200690076006e0069006e00670020006100660020006800f8006a0020006b00760061006c0069007400650074002e0020004400650020006f007000720065007400740065006400650020005000440046002d0064006f006b0075006d0065006e0074006500720020006b0061006e002000e50062006e00650073002000690020004100630072006f00620061007400200065006c006c006500720020004100630072006f006200610074002000520065006100640065007200200035002e00300020006f00670020006e0079006500720065002egt13 DEU 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 ESP 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 ETI 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 FRA 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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN ltFEFF004b0069007600e1006c00f30020006d0069006e0151007300e9006701710020006e0079006f006d00640061006900200065006c0151006b00e90073007a00ed007401510020006e0079006f006d00740061007400e100730068006f007a0020006c006500670069006e006b00e1006200620020006d0065006700660065006c0065006c0151002000410064006f00620065002000500044004600200064006f006b0075006d0065006e00740075006d006f006b0061007400200065007a0065006b006b0065006c0020006100200062006500e1006c006c00ed007400e10073006f006b006b0061006c0020006b00e90073007a00ed0074006800650074002e0020002000410020006c00e90074007200650068006f007a006f00740074002000500044004600200064006f006b0075006d0065006e00740075006d006f006b00200061007a0020004100630072006f006200610074002000e9007300200061007a002000410064006f00620065002000520065006100640065007200200035002e0030002c0020007600610067007900200061007a002000610074007400f3006c0020006b00e9007301510062006200690020007600650072007a006900f3006b006b0061006c0020006e00790069007400680061007400f3006b0020006d00650067002egt13 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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Page 39: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 36

Whether the registrant has shared energy consumption and water withdrawal targets

Whether the registrant establishes requirements that any tenant works should meet standards

provided by the registrant related to energy consumption water efficiency and indoor

environmental quality

Whether the registrant establishes requirements that its tenants provide accurate information

required for mandatory energy rating schemes

Whether the registrant has the ability to prioritize sustainability requirements over minimizing the

costs of improvements and adjustments

bull Whether the registrant prioritizes separately metering or submetering tenant energy consumption and

water withdrawals and if so if the registrant also prioritizes its own ability to measure the energy

consumption and water withdrawals by its tenants

bull Whether the registrant prioritizes lease structures that require tenants to pay grid electricity and water

utility expenses that are directly based on their actual and exclusive consumption of such resources

94 The registrant shall include a discussion of its support participation and usage of third-party initiatives

concerning green leases

bull Third-party initiatives concerning green leases include but are not limited to green lease templates

principles requirements strategies and educational programs provided by organizations

bull Examples of third-party initiatives concerning green leases include but are not limited to

Green Lease Leaders and Green Lease Library (programs jointly operated by the Institute for

Market Transformation and the US Department of Energyrsquos Better Building Alliance)

Building Owners and Managers Association International ldquoCommercial Lease Guide to

Sustainable and Energy Efficient Leasing for High-Performance Buildingsrdquo

Natural Resources Defense Council ldquoEnergy Efficiency Lease Guidancerdquo

Corporate Realty Design amp Management Institute ldquoModel Green Leaserdquo

US General Services Administration ldquoGreen Lease Policies and Proceduresrdquo

California Sustainability Alliance ldquoGreen Leases Toolkitrdquo

Real Property Association of Canada ldquoGreen Office Leasesrdquo and

US Green Building Council ldquoGreen Office Guide Integrating LEED into Your Leasing Processrdquo

and ldquoGreening Your Leaserdquo

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 DAN 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 DEU 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 ESP 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 ETI 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 FRA ltFEFF005500740069006c006900730065007a00200063006500730020006f007000740069006f006e00730020006100660069006e00200064006500200063007200e900650072002000640065007300200064006f00630075006d0065006e00740073002000410064006f00620065002000500044004600200070006f0075007200200075006e00650020007100750061006c0069007400e90020006400270069006d007000720065007300730069006f006e00200070007200e9007000720065007300730065002e0020004c0065007300200064006f00630075006d0065006e00740073002000500044004600200063007200e900e90073002000700065007500760065006e0074002000ea0074007200650020006f007500760065007200740073002000640061006e00730020004100630072006f006200610074002c002000610069006e00730069002000710075002700410064006f00620065002000520065006100640065007200200035002e0030002000650074002000760065007200730069006f006e007300200075006c007400e90072006900650075007200650073002egt13 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL ltFEFF0055007300740061007700690065006e0069006100200064006f002000740077006f0072007a0065006e0069006100200064006f006b0075006d0065006e007400f300770020005000440046002000700072007a0065007a006e00610063007a006f006e00790063006800200064006f002000770079006400720075006b00f30077002000770020007700790073006f006b00690065006a0020006a0061006b006f015b00630069002e002000200044006f006b0075006d0065006e0074007900200050004400460020006d006f017c006e00610020006f007400770069006500720061010700200077002000700072006f006700720061006d006900650020004100630072006f00620061007400200069002000410064006f00620065002000520065006100640065007200200035002e0030002000690020006e006f00770073007a0079006d002egt13 PTB 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 RUM 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 RUS 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Page 40: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 37

95 The registrant shall describe whether third-party initiatives concerning green leases are integrated into its

standard lease contracts (generally aligned with GRESB Real Estate Assessment Q391)

96 The registrant shall discuss how the lease types it uses (eg triple-net full-service) and their provisions

(eg cost recovery clauses tenant fit out guides utility information sharing mandatory participation in

energy ratings etc) may influence or incentivize tenant behavior related to sustainability impacts

bull The registrant may provide a discussion of how such lease structures may impact property values

including tenant demand and the associated rental rates and occupancy rates over the long term

97 The registrant shall consider the 2016 GRESB Real Estate Assessment as a normative reference thus any

updates made year-on-year shall be considered updates to this guidance

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 ESP 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 ETI 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 FRA 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 GRE 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 HEB ltFEFF05D405E905EA05DE05E905D5002005D105D405D205D305E805D505EA002005D005DC05D4002005DB05D305D9002005DC05D905E605D505E8002005DE05E105DE05DB05D9002000410064006F006200650020005000440046002005D405DE05D505EA05D005DE05D905DD002005DC05D405D305E405E105EA002005E705D305DD002D05D305E405D505E1002005D005D905DB05D505EA05D905EA002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002E05D005DE05D905DD002005DC002D005000440046002F0058002D0033002C002005E205D905D905E005D5002005D105DE05D305E805D905DA002005DC05DE05E905EA05DE05E9002005E905DC0020004100630072006F006200610074002E002005DE05E105DE05DB05D90020005000440046002005E905E005D505E605E805D5002005E005D905EA05E005D905DD002005DC05E405EA05D905D705D4002005D105D005DE05E605E205D505EA0020004100630072006F006200610074002005D5002D00410064006F00620065002000520065006100640065007200200035002E0030002005D505D205E805E105D005D505EA002005DE05EA05E705D305DE05D505EA002005D905D505EA05E8002Egt13 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH ltFEFF004e006100750064006f006b0069007400650020016100690075006f007300200070006100720061006d006500740072007500730020006e006f0072011700640061006d00690020006b0075007200740069002000410064006f00620065002000500044004600200064006f006b0075006d0065006e007400750073002c0020006b00750072006900650020006c0061006200690061007500730069006100690020007000720069007400610069006b007900740069002000610075006b01610074006f00730020006b006f006b007900620117007300200070006100720065006e006700740069006e00690061006d00200073007000610075007300640069006e0069006d00750069002e0020002000530075006b0075007200740069002000500044004600200064006f006b0075006d0065006e007400610069002000670061006c006900200062016b007400690020006100740069006400610072006f006d00690020004100630072006f006200610074002000690072002000410064006f00620065002000520065006100640065007200200035002e0030002000610072002000760117006c00650073006e0117006d00690073002000760065007200730069006a006f006d00690073002egt13 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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Page 41: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 38

Climate Change Adaptation

Description

Climate change affects companies in the industry via frequent or high-impact extreme weather events and

changing climate patterns The manner in which a companyrsquos business model is structured to incorporate ongoing

assessments of climate change risks and the adaptation to such risks is likely to be increasingly connected to

company value over the long term More specifically investment strategies with assets located on floodplains and

in coastal regions that are exposed to inclement weather may have increased needs around risk mitigation and

business model adaptation to climate change over the long term These strategies are especially important in light

of the long-term challenges associated with flood insurance rates the financial stability of government-subsidized

flood insurance programs and financing stipulations or other creditor concerns Besides insurance other risk

mitigation measures include improvements to physical asset resiliency and lease terms that transfer risk to tenants

although these measures can create their own costs and risks for real estate companies To ensure long-term

growth and protection in shareholder value companies need to implement climate change adaptation strategies

that are comprehensive account for trade-offs between various risk mitigation strategies and integrate

consideration of all projected costs and benefits over the long term

Accounting Metrics

IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector

98 The registrant shall disclose the total leasable floor area of properties in the registrantrsquos portfolio that are

located in special flood hazard areas where

bull FEMA Special Flood Hazard Areas (SFHA) are defined as land areas covered by the floodwaters of the

base flood on National Flood Insurance Program (NFIP) maps An SFHA is an area where the NFIPrsquos

floodplain management regulations must be enforced and where the mandatory purchase of flood

insurance applies The SFHA includes Zones A AO AH A1-30 AE A99 AR ARA1-30 ARAE

ARAO ARAH ARA VO V1-30 VE and V Examples of SFHAs include coastal floodplains

floodplains along major rivers and areas subject to flooding from ponding in low-lying areas

bull The scope of disclosure includes properties located in the US that are designated by FEMA as SFHA

as well as properties located outside of the US

bull For non-US properties that fall outside of the scope of FEMA the foreign equivalent is the area that

will be inundated by a flood event that has a one-percent chance of being equaled or exceeded in any

given year (ie the 100-year floodplain)

99 Number of units may be used in place of floor area in the Apartments and LodgingResorts property

subsectors when floor area is not available

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 GRE 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 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF 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Page 42: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 39

100 The registrant shall disclose the area of properties located in FEMA SFHAs separately for each portion of its

portfolio where properties are classified into subsectors that are aligned with the FTSE NAREIT Classification

System and include the following Health Care Self Storage Industrial Office Apartments Manufactured

Homes Single Family Homes Shopping Centers Regional Malls Free Standing LodgingResorts Specialty

Data Centers and Other (any other property type(s) that cannot be classified to any of the previous

property subsector classifications)

101 The registrant should separately provide the planned leasable floor area of properties under development

or construction that are located in FEMA SFHAs

102 The registrant may disclose its risk perception and potential impacts resulting from reclassification of FEMA

SFHAs including the risk of expansion of such areas into real estate property owned by the registrant

IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks

103 The registrant shall discuss the risks andor opportunities that are presented to its portfolio by climate

change scenarios including where relevant

bull Identification of the risks presented by climate change including but not limited to availability of

water extreme weather events evolving regulation and legislation impacts on regional infrastructure

and impacts on local economies and populations regardless of the impact of physical risks presented

to the registrantrsquos portfolio

bull Discussion of the scenarios used to determine the risks and opportunities presented by climate

change

bull Discussion of how such scenarios will manifest (eg effects directly on the registrant or effects on the

registrantrsquos tenants)

bull The timeline over which such risks and opportunities are expected to manifest

bull How risks and strategies may differ by property subsector

bull How risks and strategies may differ by region

104 The registrant shall discuss efforts to assess and monitor the impacts of climate change and the related

strategies to alleviate andor adapt to any risks andor utilize any opportunities where

bull Alleviation strategies include but are not limited to use of property insurance flood insurance lease

structures and lease durations

bull Adaptation strategies include but are not limited to physical asset resiliency and contingency plans

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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Page 43: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

copy 2016 SASBtrade SUSTAINABILITY ACCOUNTING STANDARD | REAL ESTATE OWNERS DEVELOPERS amp INVESTMENT TRUSTS | 40

105 The registrantrsquos discussion shall include a differentiation between physical asset risk and financial risk in

order to focus on the risks and alleviation andor adaptation strategies that are most likely to impact

company value

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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Page 44: Sustainability Accounting Standards Board - REAL ...Sustainability Accounting Standard, SASB identifies accounting metrics. SASB recommends that each company consider using these sustainability

SUSTAINABILITY ACCOUNTING STANDARDS BOARDreg

1045 Sansome Street Suite 450

San Francisco CA 94111

4158309220

infosasborg

wwwsasborg

copy 2016 SASBtrade

  • INTRODUCTION
  • Purpose amp Structure
  • Industry Description
  • Guidance for Disclosure of Sustainability Topics in SEC Filings
    • 1 Industry-Level Sustainability Topics
    • 2 Company-Level Determination and Disclosure of Material Sustainability Topics
    • 3 Sustainability Accounting Standard Disclosures in Form 10-K
      • b Other Relevant Sections of Form 10-K
      • c Rule 12b-20
          • Guidance on Accounting for Sustainability Topics
          • Users of the SASB Standards
          • Scope of Disclosure
          • Reporting Format
            • Use of Financial Data
            • Activity Metrics and Normalization
            • Units of Measure
            • Uncertainty
            • Estimates
              • Timing
              • Limitations
              • Forward-looking Statements
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics
              • Table 1 Sustainability Disclosure Topics amp Accounting Metrics (cont)
              • Energy Management
                • Description
                • Accounting Metrics
                  • IF0402-01 Energy consumption data coverage as a percentage of floor area by property subsector
                  • IF0402-02 Total energy consumed by portfolio area with data coverage percentage grid electricity and percentage renewable each by property subsector
                  • IF0402-03 Like-for-like change in energy consumption of portfolio area with data coverage by property subsector
                  • IF0402-04 Percentage of eligible portfolio that (1) has obtained an energy rating and (2) is certified to ENERGY STARreg by property subsector
                  • IF0402-05 Description of how building energy management considerations are integrated into property investment analysis and operational strategy
                      • Water Management
                        • Description
                        • Accounting Metrics
                          • IF402-06 Water withdrawal data coverage as a percentage of total floor area and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-07 Total water withdrawn by portfolio area with data coverage and percentage in regions with High or Extremely High Baseline Water Stress each by property subsector
                          • IF0402-08 Like-for-like change in water withdrawn for portfolio area with data coverage by property subsector
                          • IF0402-09 Discussion of water management risks and description of strategies and practices to mitigate those risks
                              • Management of Tenant Sustainability Impacts
                                • Description
                                • Accounting Metrics
                                  • IF0402-10 Percentage of new leases that contain a cost recovery clause for resource efficiency-related capital improvements and associated leased floor area by property subsector
                                  • IF0402-11 Percentage of tenants that are separately metered or submetered for (1) grid electricity consumption and (2) water withdrawals by property subsector
                                  • IF0402-12 Description of approach to measuring incentivizing and improving sustainability impacts of tenants
                                      • Climate Change Adaptation
                                        • Description
                                        • Accounting Metrics
                                          • IF0402-13 Area of properties located in FEMA Special Flood Hazard Areas or foreign equivalent by property subsector
                                          • IF0402-14 Description of climate change risk exposure analysis degree of systematic portfolio exposure and strategies for mitigating risks
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 ESP 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 ETI 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 FRA 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 GRE ltFEFF03a703c103b703c303b903bc03bf03c003bf03b903ae03c303c403b5002003b103c503c403ad03c2002003c403b903c2002003c103c503b803bc03af03c303b503b903c2002003b303b903b1002003bd03b1002003b403b703bc03b903bf03c503c103b303ae03c303b503c403b5002003ad03b303b303c103b103c603b1002000410064006f006200650020005000440046002003c003bf03c5002003b503af03bd03b103b9002003ba03b103c42019002003b503be03bf03c703ae03bd002003ba03b103c403ac03bb03bb03b703bb03b1002003b303b903b1002003c003c103bf002d03b503ba03c403c503c003c903c403b903ba03ad03c2002003b503c103b303b103c303af03b503c2002003c503c803b703bb03ae03c2002003c003bf03b903cc03c403b703c403b103c2002e0020002003a403b10020005000440046002003ad03b303b303c103b103c603b1002003c003bf03c5002003ad03c703b503c403b5002003b403b703bc03b903bf03c503c103b303ae03c303b503b9002003bc03c003bf03c103bf03cd03bd002003bd03b1002003b103bd03bf03b903c703c403bf03cd03bd002003bc03b5002003c403bf0020004100630072006f006200610074002c002003c403bf002000410064006f00620065002000520065006100640065007200200035002e0030002003ba03b103b9002003bc03b503c403b103b303b503bd03ad03c303c403b503c103b503c2002003b503ba03b403cc03c303b503b903c2002egt13 HEB 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 HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 LVI 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SVE 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