STATEMENT OF JOHN M. McGINTY, VICE PRESIDENT AND CHAIRMAN, ENERGY COMMITTEE, THE AMERICAN INSTITUTE OF ARCHITECTS, ACCOMPANIED BY JOHN EBERHARD, PRESIDENT, AMERICAN INSTITUTE OF ARCHITECTS RESEARCH CORP. Mr. McGINTY. I would like to introduce John Eberhard, president of AIA Research Corp. After commenting on the three bills under consideration, we would also like to address the issue of energy conservation standards in a general way. The American Institute of Architects endorses the adoption of longterm, comprehensive energy conservation policies for all sectors of the economy. Buildings, as the second largest energy-consuming sector, offer a significant opportunity to save energy. Government at all levels can set examples for the Nation in conserving energy in existing buildings by means of retrofitting and by having new buildings designed to be energy efficient. Senator MORGAN. Let me interrupt. Five bells have sounded and I have got to go. If you do comment in connection with your prepared remarks, I wish you would do so to Mr. Purinton, with regard to what effect you think these mandatory guidelines might have on your profession. Also, would their effect spill over into commercial areas? Again, I apologize for having to go, but I have no choice. If my people read in the paper on Sunday morning that I didn't vote on this bill, I would catch more from them than from you, believe me. Mr. Purinton, what you do now is for the record. Mr. MCGINTY. We believe that solar energy, both its direct and indirect use in buildings, is a high priority concern deserving of major support by Congress. We also endorse the concept of life-cycle costing in the evaluation of energy design alternatives. The AIA supports the general purpose and intent of S. 2045, the Federal Facilities Energy Conservation and Utilization Act, and S. 2095, the Conservation and Solar Energy-Federal Buildings Act. We would, however, raise some cautions about several of the provisions in the legislation. Life-cycle energy costs as defined in S. 2095 makes an assumption that if the cost of energy-consuming equipment, the operating costs and the maintenance costs are all positive, energy use will be reduced. That is not always true. Therefore, professional judgment will be required in the use of lifecycle energy cost analysis. The AIA would be happy to cooperate in a joint venture with other professional organizations to develop energyeffective methods for this purpose. We are also concerned that the energy use analyses call for consideration of the amount of energy required to produce and transport materials used in construction. This is certainly a logical requirement; unfortunately, sufficient data to do it are not yet available. We question the sections in which new techniques for energy supply, generation, and transmission are listed as considerations in an energy use analysis. With so many new ideas emerging daily, when does one reach the point where consideration of alternatives should be suspended? These and other examples suggest that legislation such as S. 2045 and S. 2095 should be less specific with respect to the methodology of energy analysis and life-cycle cost calculations. The provisions of section 4 of S. 2095 which call for energy guidelines for Federal buildings to be built or renovated scem plausible. The AIA Research Corp. has worked with the General Services Administration in the early development of such guidelines. GSA's early recognition of the need for energy guidelines and their support of work to produce them has resulted in published documents. Those that are now available are: "Energy Conservation Guidelines for Existing Office Buildings," "Energy Conservation Design Guidelines for Office Buildings," and "Energy Conservation Design Guidelines for New Office Buildings," second edition. Regarding section 5(a) (2) of S. 2095 which authorizes a 1-year effort to produce an inventory and energy use analysis of all existing buildings under Federal jurisdiction, we recommend that a statistically significant sample be done first. This would indicate the cost/ benefit ratio of doing an analysis for every building. If we are to advocate the use of tools such as life-cycle energy cost analysis and energy use analysis, then it would seem wise to test them first on a few demonstration projects. The demonstration program proposed in S. 1392, the Energy Conservation in Buildings Demonstration Act, could lend itself to that purpose. Therefore, the American Institute of Architects supports the intention, concept, and program plan described in this legislation. As in the case of S. 2045 and S. 2095, we have some modifications to recommend. Of major concern to achitects is a currently prevalent misconception that the reason buildings use energy is because they have mechanical and electrical systems. The prior question is: Why do buildings have mechanical and electrical systems? The answer is: To provide for human comfort. The comparatively recent availability of such systems to provide for human comfort has overshadowed some basic design principles. Such principles at one time permitted widespread use of architectural solutions to the problems of human comfort without heavy, if any, reliance on mechanical systems sustained by nonrenewable energy sources. Therefore, we suggest that the emphasis in S. 1392 to energy conservation equipment and systems ignores a whole range of architectural decisions which could reduce energy consumption. For example, architectural decisions which could reduce energy consumption. For example, architectural redesign could include modifying existing office arrangements, changing or adding windows or light-wells, providing protection from sun glare by exterior sunshades, and modifying fixed windows in order to make it possible to open them for natural ventilation, and many other such specific examples. We recommend that a definition of energy conservation should be included in the bill. For your consideration, we suggest the following language: "Energy conservation technology means any concept, technique, equipment, or system that can be utilized in reprograming, replanning, or retrofitting existing buildings." Work done for the General Services Administration by the AIA Research Corp., as I mentioned previously, has produced documents which could provide a base for the evaluation surveys proposed in section 7, and the Institute would welcome an opportunity to participate in the evaluation phase of the demonstration program. We also offer our cooperation in disseminating information resulting from the demonstration program if it is enacted into law. The American Institute of Architects would be pleased to respond to the provisions in S. 2045 and S. 1392 which call for consultation with the administering agencies. We strongly recommend that section 4 of S. 2095 be amended to include participation by the design profession in the development of energy guidelines for Federal buildings. Turning now to the issue of energy conservation standards, AIA opposes the development of prescriptive standards for energy conservation in buildings for the following reasons: Prescriptive standards apply only to new construction, thus overlooking the entire inventory of existing buildings. Prescriptive standards do not treat one of the basic causes of energy waste; that is, existing financial and tax processes actually provide economic incentive to waste energy rather than to conserve it. Prescriptive standards, or component performance standards, as they sometimes are called, are applicable only to individual components of buildings rather than to the entire structure. They ignore the way a building is designed, assembled, and operated. In other words, the optimization of individual building parts does not necessarily result in the optimization of the entire building. Prescriptive standards which establish minimum energy conservation levels tend to establish maximum conservation levels as well, and do not encourage innovation or the development of new technology. Prescriptive standards do not utilize the ingenuity and talents of the design professions, building trades, or manufacturers. The AIA supports the development by the Federal Government of performance-based national standards for energy conservation or energy conscious design of buildings. We see such performance standards as tied to energy budgets-number of Btu's per square foot per year-for entire buildings, taking into account building types and climatic zones as moderating factors. These should be used rather than either prescriptiove standards or component performance standards, such as ASHRAE 90-75, which the AIA does not consider to be performance-based. We believe that the specific provisions of performance standards should be developed in consultation with design professionals. Nationally promulgated performance standards are preferable to the alternative-each State and/or local municipal government developing energy standards-which is likely to result in a proliferation of different requirements similar to the present situation with building codes. The American Institute of Architects is prepared to respond to any opportunity to work with the Congress and the administration on this important problem. We thank you for the opportunity to express our views. We would be happy to respond to questions now, or in writing. I am sorry that Senator Morgan had to bring the hearing to an end and rush off to vote. He did ask that you be allowed to go ahead and continue with your testimony so it would be in the record. The hearing is officially closed. [Whereupon, at 12 noon, the subcommittee recessed, to reconvene subject to the call of the Chair.] [Additional statements follow:] This is in response to your request for the views of this Section 4 of S. 2045 would direct the Administrator of General Section 5 of the bill would require preparation of an energy With respect to the issuance of energy conservation guidelines for Federal buildings, we defer to the General Service Administration as to whether legislation in this regard is necessary or desirable in view of ongoing activities directed toward development of standards and increasing the energy efficiency of all Federal facilities and operations. However, we would have serious reservations regarding the application of the proposed guidelines to Federally assisted housing. In Section 526 of the National Housing Act already requires this Department to establish minimum property standards to promote the use of energy saving techniques in the construction of residential housing covered by HUD-insured mortgages. In order to qualify for loans and loan guarantee and insurance under programs administered by HUD, the Farmers Home Administration and the Veterans Administration, residential structures must meet the Minimum Property Standards (MPS) published by HUD's Office of Housing Production and Mortgage Credit. recent years, the sections of the HUD MPS dealing with the thermal performance of residential structures have been upgraded in 1972 for multifamily dwellings and on November 22, 1974 for single family dwellings. Most significantly, HUD has also monitored and participated in standards development activities undertaken by independent professional societies such as the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and is currently reviewing the recently published ASHRAE standard 90-75 for potential use in part of the MPS. In addition, this Department is also charged, under the Solar Heating and Cooling Demonstration Act of 1974, with the development of performance criteria for solar heating and cooling of dwellings and other buildings. Interim performance criteria have already been published under this Act, and while our current schedule does not contemplate the issuance of definitive performance criteria for at least two years, we are working with the National Bureau of Standards and other agencies and organizations to develop intermediate 'minimum property standards" for solar systems within a year. |