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those pilot lights. We suggest turning them out, supplying everybody with matches, and you can save one-half percent of the national consumption. In any case, when those appliances are available, they will be installed. Additionally, the National Association of Home Builders has a little booklet which I don't have with me, "Your New Home and How to Take Care of It," which is given by builders to purchasers of new homes as part of the closing package. This particular document is up for review at this time and I am certain that we will include in it a section on emphasis of savings in home operating costs through energy conservation. We will list certainly some of the partices shown in

the slides this morning.

We suggest that must greater emphasis on conservation needs to be directed toward existing structures, both homes and commercial, around the country. We believe there is much room for improvement in those facilities. Of course, that will require a real selling job, a different kind of selling job than that necessary when you put these improvements in new structures, and it might require direct economic incentives, such as a tax break, for the amount spent in improvements which contribute to energy conservation. But, basically, adding insulation under existing roofs is a fairly simple job and more effective than adding insulation to walls, and while we believe that homes, older homes, are poorly insulated, we also believe that there are a great number of commercial structures that are in need of improved insulation also. It is also suggested, as I mentioned earlier, that even greater results can be achieved in energy conservation in other areas and that we mustn't forget that improvements in home energy consumption mustn't stand alone. I know you are not concerned with transportation, but consider that one ton of freight shipped by truck consumes 6 times as much energy as shipping that same ton by rail. Just a little change in shipping patterns could result in significant savings.

One final thought. It also seems inconsistent to be working so hard on energy saving in homes and buildings when Detroit has just had its biggest quarter of production of automobiles that consume more energy than ever.

NAHB is in favor of energy conservation. It is recommended however, that all means of conservation be explored and that those which achieve the greatest results in the quickest time be given the highest priority. We do want to assure you that we want to work with all of you to achieve the desired results in our sector, home building. Thank you.

Dr. J. E. Snell

The last of our resource speakers is Wilbur D. Sparks, the Director of Legislative Affairs, American Refrigeration Institute.

Wilbur D. Sparks

The Air Conditioning and Refrigeration Institute is an industry trade association, which represents more than 90 percent of the U. S. made equipment used in air conditioning systems and refrigeration systems, and consists of 183 manufacturers of these systems and their components. ARI is very interested in one of the principal subjects for this morning's discussion--efficiency in air conditioning and refrigeration. Most of what I have to say will be brief, I assure you, and will deal with air conditioning.

I want to emphasize first that an air conditioning system is more than an air conditioner, and that efficiency in air conditioning has to come not only from design of the air conditioning unit itself, but also from design of the duct work, and from the location and the insulation of the home in which the system is installed. The efficiency with which the system is used depends a great deal on the life-style of the family if it is in a home, or the work habits of the people in the office building where it is being used.

When you are talking about efficiency, a great deal depends on factors other than the efficiency of the unit itself. That is the point at which the manufacturer has control over the efficiency of the unit. But he and the user depend very heavily on the installer, the contractor, the designer who determines what size unit, what the insulation is going to be, what the glazing is going to be, all of the factors that go into the question of how efficient the unit will be. Much of this is out of control of the manufacturer.

ARI is currently certifying a number of different types of units that its manufacturers make. By certification, I mean setting up testing standards which are carried out by independent testing laboratories. These tests will show, for instance, the power input and the btu output. Now ARI is currently certifying the power input for unitary air conditioning equipment. We have a directory which will show this for all types and sizes of air conditioning equipment produced by our members. Anyone who would like to have a copy of this can contact us and get it or the directory for any of our other certification programs. So far as we know, none of our members are placing this kind of information on a label. I bring this up because there is coming to the forefront some emphasis on labels.

Through its appropriate committees, ARI is studying the possible publication of performance factors in its directory of unitary air conditioners. That would be expressed in btu's per watt hour. We are being held up right at the moment by one problem, and while I am sure this will be solved, it does illustrate the kind of complication that goes into studying performance. Before you can lay out a performance factor, you have to take into consideration that in the home the most commonly used type of residential air conditioning equipment doesn't include the fan for circulating the conditioned air. Instead, the furnace fan is used for this purpose. This furnace fan isn't a part of the air conditioner and the watt input rating of the air conditioner, therefore, doesn't include the power consumption of this fan. Because of this, the power consumption for the equipment itself doesn't reflect the energy requirement for the entire air conditioning system. I imagine that in fairly short order we will get this problem solved, and we will be publishing performance factors for each of the unitary air conditioning systems put out by our members.

I do want to dwell very briefly on the Federal labeling program and the emphasis on labeling programs which is coming to the forefront. I think these will be increasingly talked about in the future. Many of you know that coming out of the President's message, the Department of Commerce on June 5 published in preliminary form in the Federal Register, a voluntary labeling program which would call for the manufacturers of household appliances to provide to consumers, at the point of sale, certain information on the energy consumption and the efficiency of major household appliances. The preliminary draft of this regulation includes central air conditioning as a major household appliance. There may be a problem here because, while a unitary system can have a rated efficiency when it leaves the manufacturer, there are many factors entering into its ultimate efficiency. We see some problems in working out a labeling system that will be meaningful and will make it possible for consumers to compare, by cost or otherwise, the energy consumption and the efficiency characteristics when purchasing central air conditioning systems.

I had a few remarks, gentlemen, dealing with design and dealing with some technical aspects of this subject, but in view of the lateness of the hour and in view of the fact that I am not really an expert in that area and am somewhat overwhelmed by what we have heard and seen here this morning, I am not going into this. I want to emphasize that ARI is available as a resource to any of the code people or other people, here. We would be glad to provide you with any information that we have in dealing with the extraordinarily difficult problem of energy conservation. Thank you.

Dr. J. E. Snell

I am sorry to report that the Home Appliance Manufacturers representative could not be with us today. I will now open the floor for some discussion, if there is someone who wishes to be heard.

Joseph Tone

I am from the State of Washington. In hearing these discussions this morning I began to wonder if there is a resource in Washington, D. C., in which plans for expanded State construction could be submitted for a critical review and analysis bringing out the findings you have had in these various technical evaluations you have had in the Is it possible to submit these completed plans for State build

Washington, D. C., area.

ings and have them critically analyzed?

Dr. J. E. Snell

That is a good question. I think the best answer derives from Mr. Phillips' opening remarks. That is, the research results that we are talking about, the methodology, the computer programs and so on, are rapidly becoming a part of the stock in trade of the designers and professionals in this field, and if called upon to produce in these areas I believe they can do these same things for you.

Alonzo Westbrook

I am the State Mechanical Engineer for the State of Tennessee. I would like to interject myself at this point to answer this question, in that our State Architect's Office performs exactly that function for reviewing all of our State buildings. I would say that if any of you gentlemen have similar questions, you should direct them toward either your State Architect's Office or your State Building Codes Office. I say that there are already organizations structured to perform that function.

Dr. J. E. Snell

I would hasten to add that the survey of State actions and State activities that will be on the program in the afternoon session will highlight such activities that are underway.

Kenneth C. Henke, Jr.

At this time, it is my pleasure to introduce to you Mr. Paul R. Achenbach, Chief, Building Environment Division, National Bureau of Standards. Mr. Achenbach will speak to us on Mechanisms for Implementation of Energy Conservation Technology in Buildings.

Remarks and copies of slides and transparancies used can

be found in NBS Technical Note 789--"Technical Options for
Energy Conservation in Buildings," pp. 146-172.

(Mr. Kenneth Henke introduced Mr. Israel Resnick from the American National Standards Institute. Mr. Resnick explained ANSI's principal objectives and some of the methods used in developing and approving standards as American National Standards.)

Kenneth C. Henke, Jr.

I am happy to report to you that 23 out of 50 States, plus the District of Columbia, are in attendance here today. The States present represent two-thirds of the population of the Nation, so I feel we are reaching the majority of the people.

I would like to present Mr. Joseph Stein, past Building Official of the City of New York.

Joseph Stein

Thank you, Ken, for your kind introduction. Before I get to my main subject--that of energy conservation relating to design and construction and the problem role of

building codes and standards--I would like to share some of my own code experiences and then develop a thumbnail history of codes. I'll also try to define some terms for those of you who are new to the subject.

For a little background on myself, I left private practices about seven and one-half years ago to work for New York State, which I was Assistant Commissioner for Planning and Construction, in charge of its low- and middle-income housing programs. Before that and for more years than I'd care to admit, while in the private sector, I was involved in construction and consulting engineering. At the beginning of 1971, I was asked to take over as Commissioner of the New York City Building Department, which is the largest in the United States (and I guess in the world), with all of its problems and challenges.

While in the private sector, I, like most of my colleagues, regarded regulatory agencies as unnecessary constraints. However, I've learned a lot after having been exposed to the problems of the other side, and I'm willing to admit I was at least partially wrong. My involvement with NCS BCS is an exiguous extension of my previous involvement with New York State. I saw hope in NCSBCS for achieving order out of the chaos and nonuniformity of code requirements, a favorite target of the codes critics.

The Douglas Commission did its famous study on industrialized housing and identified the literally thousands of independent code entities as one of the major constraints to innovation and the free interstate movement of industrialized housing units and components. It is amusing to hear some of the very same people who condemned the codes for inhibiting innovation, now calling for the codes to become the surrogate for design in this very important energy issue.

I was

As a member of the Standards and Evaluation Committee of NCSBCS, I presented a resolution last year, while still Building Commissioner, to consider the potential problem of non-uniform and arbitrary code requirements dealing with energy and building design. Here was a perfect opportunity to deal with a problem before it surfaced. reasonably certain that this was an issue that would become politically attractive i.e., code requirements on energy) and I fought one of the early battles in New York City against such arbitrary building code amendments.

I don't intend using a prepared text, since I usually prepare one then deviate from it and wind up accused of being a "text" deviate. I was given an hour and a half on the program, and I certainly don't intend to speak an hour and a half. I would like to fill in those of you who are representing the Governors of your States, who are either new to the problem or are not architects or engineers. I hope I can give you a little background on codes problems and philosophy so that you all understand what we are talking about.

Building codes and building departments, or whatever they are called in your particular neck of the woods, are all products of "laissez-faire." Decisions affecting public safety were made by those who had a financial interest in what they were building and often the decisions were less than objective. As a result, government was brought into the picture and, while I shouldn't use the expression white hat or black hat, the group who came in wearing white hats to protect the public, as time went on, became more involved with regulation and eventually became the enemy, loaded with bureaucratic red tape, delays, arbitrary requirements, graft, etc., and were now considered constraints instead of saviors. Certainly, the pendulum had swung too far towards government regulation, especially in areas where we should depend more heavily on the design professional. In New York City we tried to put more responsibility on the design professionals and left to government the responsibility of monitoring their performance. As Building Commissioner, I also became aware of the fact that the legislators could pass all sorts of good laws, but if you as regulators don't have the resources to implement them, it's like having no laws at all. I also found great duplication of effort, particularly when a new problem surfaced and insufficient research or data were at hand, for example, the fire safety regulation in tall buildings. We did our own thing in

New York, as did Chicago, San Francisco, Boston and Los Angeles, to name a few. reinventing the wheel, but in a slightly different way.

Each was

The "old" code philosophy, called the specification or the prescription approach, told exactly "how to" design or construct. This relatively inflexible approach, of course, can create headaches for the innovator, but it can also be the panacea for the understaffed regulatory agency or the engineer whose fee is too low to innovate.

Modern code philosophy relies on the performance approach and most progressive code groups recognize this more flexible method. Rather than being told exactly how to do something, you are now only told how the something shall perform, and of course, this approach presents problems too. It requires both expertise and a willingness to innovate by the design professions and at the regulatory end, you must also have people capable of interpreting performance, determining whether a design or construction actually does meet the required performance. This is a big problem from the regulatory point of view, that of enforcing a performance code, but be that as it may, most large or progressive regulatory agencies have adopted performance or partial performance codes.

The New York City code, for example, which is a relatively new one, passed in 1968, references to over 300 nationally-accepted standards, many of which were generated through national consensus procedures. Now this approach, I think, is a very practical first step to attaining nationwide uniformity. I don't think for the time being that a national code is practical or attainable, since the responsibilities of safety, health and welfare protection of the people are left to the States.

Traditional code philosophy concerns itself with the immediate safety of the occupants of a structure, or those in the immediate vicinity of the structure. You people sitting here should be protected from the floor collapsing and in case of fire, you should not be too far from an exit. The energy question and its possible inclusion into the codes presents a departure from this viewpoint. We also have to understand the difference between a code and a design standard. A "building code" generally addresses itself to minimum requirements to assure safety--no more, no less. A "design standard," however, is the prerogative of the owner or someone else who has a financial interest in a project. He is interested in additional performance of the structure beyond the minimum safety requirements for the occupants and he states his additional design requirements in a "design standard." To put the FHA Minimum Property Standards into proper perspective, they are more properly classified as a "design standard" rather than a "building code."

I hope I haven't lost you all with the code jargon and philosophy, but it is necessary background to understand the magnitude of the problems that can be created if the energy crisis is not properly managed in relation to building regulation. If we assume that codes are going to be administered locally or statewide or by the big cities within the States in parallel with the States, and if we assume that all the codes reference to the same national standards, we will in fact have achieved a high degree of uniformity. What would be acceptable in one area, automatically becomes accepted in

another.

The important question of energy related design control by the building codes can be handled in this fashion. If, in fact, a strategy was organized to develop a national standard through consensus procedures, it would take at least a year to accomplish. Any regulatory body that wished to legislate in this energy area could reference to a national energy standard, so that for example, what is required in New York will be automatically the same as required in California (and all points in between).

I really got interested in this particular issue in the latter part of 1971, when I read a release that New York State was contemplating legislation dealing with the design and siting of buildings to conserve energy. Many manufacturers and interested groups got on the band wagon. The Masonry Council advertised masonry buildings to help conserve energy. The Producer's Council had a traveling road show on the many insulating products

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