The Bureau of Overseas Building Operations sent a memo restricting sustainability language for architects
As part of the Trump administration’s editorial revisionism, agencies like the Department of State are seeking to change how architects can publish and describe the work they complete for the federal government. AN recently learned of a communication aimed at revisiting previously approved content for release and altering language about sustainability for projects completed by the Overseas Building Operations, which is “the single real property manager for the planning, acquisition, design, construction, operations, maintenance, and disposal of U.S. governmental diplomatic and consular property overseas.”
Dated February 19, 2025, and directed to “all prime and subcontractors supporting projects for the Overseas Building Operations (OBO),” the memo subjects new releases to “re-review”: “Any content cleared prior to January 20, 2025, that is included in new public-facing materials must be submitted for re-review and clearance to ensure alignment with current executive orders aimed at making the United States stronger, safer, and more prosperous.”
Additionally, the memo stated that before resubmission, “all references to sustainability or diversity, equity, and inclusion (DEI) shall be removed.”
The memo also directed the removal of sustainability language:
Sustainability features should be framed through the lens of the new administration’s priorities by:
Focusing on building performance
Using language like “adaptation” rather than “resilience”
Removing the terms “LEED,” “climate,” and “sustainability”
AN has reached out to architecture firms with projects under construction with the OBO for comment to learn more about how this change to sustainability language affects their work. Words like “climate crisis,” “climate science,” and “diversity,” among others, appear on an incomplete list of words that have been flagged to “limit or avoid,” according to reporting in The New York Times.
Already, one consulate project was submitted to AN for coverage but was then placed on hold as press material was required to be resubmitted for review. “Due to NDAs and client confidentiality,” the architect was not able to speak with AN about this process, according to a spokesperson.
When asked for comment last month, a representative from the USGBC was not aware of the memo.
The OBO is the client for major U.S. embassy and consulate projects around the world designed by the country’s leading architects. Projects with budgets totaling billions of dollars are currently under construction: Richärd Kennedy Architects is designing a new consulate in Rio de Janeiro, as well as an embassy in Qatar (with a budget of $336 million) and one in Mauritius ($301 million). Ennead is designing a new consulate in Nogales, Mexico ($203 million), and another one in Thailand ($273 million); both include Page as the architect of record. SHoP is designing a new embassy in Milan ($351.2 million). In Montenegro, the second phase of a new embassy designed by Beyer Blinder Belle with Integrus is under construction ($264.4 million).
Since FY2008, OBO required LEED certification as a “contractual requirement for all capital projects,” and as of FY2010, LEED Silver was the minimum level of achievement. There has been no news as to if this standard has been updated or abandoned during the Trump administration. As mentioned in a 2021 article in AN by A. J. Artemel, sustainability plays a “double role” in embassy projects: It is both meant to respond to climate change (largely by reducing operational energy) while mitigating practical concerns, like electrical grids that might become unreliable due to outages or unrest.
The edits to sustainability language made under the Trump administration largely shift the description to the latter category, instead of the former: Sustainability is now described as optimization or performance. Many of the projects were designed in an eco-technical manner with sustainability as a major design driver, so it remains to be seen how the projects’ key aspects will be promoted. A quick review of website edits reveals how OBO project descriptions have been updated.
In Brasília, Brazil, Studio Gang is completing an embassy with Page ($556 million). A description from December 2024 mentioned the project’s “safe, secure, functional, and resilient architecture” that will provide “a sustainable and engaging space for the future of U.S.-Brazilian relations.” Now, the text substitutes “efficient” for “resilient” and removes “sustainable”—but adds the goal of making the U.S. “safer, stronger, and more prosperous.” Mention of LEED Silver has been removed, as has PROCEL, “an energy-savings certification mandated for all new Brazilian federal buildings.” A mention of the region’s “biodiversity” was also edited out of the text.
Miller Hull is designing a new embassy in Malawi. A prior description from last year had a section titled “Resilience & Stewardship” that promoted the target for LEED Gold certification; now the section omits mention of LEED and is titled “Building Performace.” (Sticklers will note that “performance” is spelled wrong.) Additionally, the mention of “diversity”—as in, “the diversity and richness of U.S. and Malawian cultural heritage”—was removed; now the embassy “embodies U.S. creativity and heritage.”
In Mexico City, a new embassy designed by Tod Williams Billie Tsien Architects with Davis Brody Bond is under construction ($943 million). In a previous version of the website, one section was dedicated to sustainability: “The new complex incorporates rigorous sustainability and energy-saving goals to reduce environmental impact, optimize building performance, and enhance resiliency.” Now the section is titled “Building Optimization” and begins: “This project reduces risk and cost associated with security and maintenance while enhancing resilience to natural hazards.” Water efficiency and low-maintenance plants are mentioned, but the prior description’s target of LEED Gold for the complex has been removed.
As recently as last September, the Department of State was praising OBO’s sustainability efforts: An article for State Magazine about a range of projects in Mexico praised the widespread use of passive shading to reduce solar heat gain.
The OBO projects mentioned above are already so far along in budget allocations and construction timelines that the physical removal of any significant sustainability components seems unlikely. What remains to be seen is if any sustainability features that aid in lowering the operating costs of buildings over their lifespans—and thus saving taxpayer dollars—will actively be removed from efforts that are earlier in the design process: The OBO portfolio portal provides links for Acquired Sites and In Planning & Design, but both web pages are listed as “currently under construction.”
AN has reached out to OBO for comment.
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