The Council on Governmental Relations (COGR), representing major research universities, submits a formal request to the Office of Management and Budget (OMB) and the Council on Financial Assistance Reform (COFAR) regarding proposed modifications to the methodology used for calculating the Utility Cost Adjustment (UCA) within the Uniform Guidance for research space. COGR commends the intent behind the UCA, which enables a more accurate and equitable allocation of utility costs to research-intensive facilities, reflecting their intrinsically higher energy demands due to continuous operation and specialized equipment. Despite acknowledging the improvements brought by the Uniform Guidance, COGR raises concern that the current Relative Energy Use Index (REUI) factor of 2.0 is based on outdated and insufficiently precise data, resulting in an understated recognition of actual utility consumption in research laboratories.
Supporting its case through updated data analyses and expert consultations, COGR details methodological flaws in both the numerator and denominator of the REUI calculation—such as reliance on estimated rather than measured data, inclusion of non-research spaces, and outdated benchmarks for campus energy use. COGR argues that, when corrected, these adjustments would yield a revised, more representative REUI factor of 4.2, as opposed to the present 2.0. The organization recommends this adjustment be made effective for Facilities & Administrative (F&A) rate proposals submitted with FY2015 data and offers to collaborate with OMB and related agencies in refining the methodology. While recognizing that allowing each institution to calculate its own REUI might provide the greatest precision, COGR maintains that a standardized and updated factor will ensure fairness and simplicity. The letter closes with a request for dialogue to facilitate prompt resolution and implementation of these adjustments.
