that could be used to conserve energy, and others. I was also invited to join the Ad Hoc Committee on Energy Efficiency in Large Buildings of the Interdepartmental Fuel and Energy Committee of the State of New York. They, too, were thinking of recommending legislation in the areas of regulating heat loss, requiring insulation, limiting fenestration and so on, all going back to the old specification approach to design. Just today, I was just handed a reprint from a recent copy of the Engineering News Record. Two cities in Ohio--Wooster and Cuyahoga Falls--have just amended their building codes regulating minimum amounts of thermal insulation required in buildings as an energy conserving measure. The Director of Administration in Wooster said of the codes, "If more cities had insulation requirements in their building standards we would do more to solve the energy crisis the nation is facing than any other single thing." While it makes for good press, the quotation is far from accurate. I happen to agree with the gentleman from the National Association of Home Builders who just commented on the immediate impact of regulating new construction and its minimal immediate contribution to solving the energy crisis. I was pressured by several groups in New York City to consider recommending adoption of the FHA Minimum Property Standards for insulation into our code. If a code were to adopt these arbitrary requirements, (and these are arbitrary as they relate to a life safety document), how could you justify adopting levels of allowable heat loss which were arrived at using a cost/benefit analysis. If, in fact, heat loss is so critical, why limit the insulation to four inches? Why not go to six or eight inches or require the building to be so perfectly sealed that you could heat them with candles? Much study has to be done in this area. If you could just consider for a moment two buildings, two hypothetically identical buildings as far as shape and configuration and occupancy. One would be a completely glass enclosed building, poorly insulated on the exterior, but with a very efficiently designed mechanical system, lighting system, heat recovery apparatus; the other building across the street, a very well insulated masonry structure, without windows, but with very poorly and inefficiently designed mechanical systems. The first building, the glass building, might very well use the same, if not less energy than the windowless building designed to satisfy arbitrary heat loss specification requirements (that only deal with the "perimeter" of the problem). The pun is intended. Whatever energy design standard is developed, of necessity, it should be a performance standard to permit the design professions as much flexibility as they require in designing the building and, at the same time, to permit them to innovate. It must also be one that can be readily and efficiently administered by the regulatory agency. I am speaking from my own personal point of view, having thought about the problem and having thought of the horrendous possibilities of a legislative body passing a law requiring "efficient" design. A complicated structure can take anywhere from several weeks to several months to be approved by the regulatory agency that is reviewing only for absolute minima related to the occupants' safety. I think you can see what problems and time delays would result from having groups of engineers and architects critiqueing each others' designs. In this area, one approach that has been proposed, which I tend to think is workable, would be the use of energy application indices as energy design requirements. Just as this very auditorium floor may be designed for 100 pounds per square foot of live load, with the ingenuity of the engineer and architect being relied upon to design a structurally sound and economical floor system, he is not told to design in steel or concrete or any other material. The minima in the area of live loads have been established based on research and experience. It is perfectly possible and feasible to establish similar surrogates to control and to monitor energy use in buildings. Traditional code philosophy, as I pointed out before, has always prevailed, justified by States' mandate (in many cases authority was passed on to the municipalities) to protect the immediate health, safety, and welfare of the occupants in and around buildings. Philosophically, energy control may be a bit difficult to accept as a code item. Codes have traditionally dealt with fire protection, structural integrity, ventilation, sanitation and of recent vintage, progressive codes have addressed themselves to noise control. Does conservation of energy immediately affect the occupants' health or safety? Does noise control? I think the traditionalists who regard codes as purely life safety documents will yield on this issue. While I don't agree with the statement of the engineer or the code administrator from one of those two Ohio communities that this will have a sizeable immediate impact, that is, I don't think controlling design in new buildings will have a sizeable immediate impact on the energy picture. I think it is something that must be done considering the long-range picture. In contrast, energy use in existing buildings and retrofitting of existing buildings, perhaps is the most significant immediate task and, perhaps the highest priority item in the area of energy conservation. Even if it takes a year or a year and a half to generate a uniform national design standards that codes could reference for new buildings, and if there could be uniformity as a result, it is worth the wait. As I said, I served on the New York State Ad Hoc Committee and their excellent report was just released. I would like to read their recommendations as far as codes in relation to energy conservation in building design and construction. This is a summary, and I would hope that you would take the same message back to your respective States. It reads, "Building Codes: an indepth study should be instituted to analyze existing building codes to determine whether they need revision in order to conserve energy. This study should be organized on a national basis using the staff and expertise of organizations such as the National Bureau of Standards. If the need for code revision is validated, then a standardized code (they use the word code, they mean standard) "for the State of New York should be developed based on minimum acceptable design and performance standards through national consensus procedures such as the American National Standards Institute..." They also mention that this standard, when it is generated may require modification to adjust to special conditions that exist in the larger urban centers, and that this should be recognized as well. This is usual procedure when a national standard is promulgated. The standard is adopted in toto if it suits the situation, but it can also be modified and amended to suit special local or geographic requirements. If an orderly approach is not taken, I can see another typical code reaction to a crisis (which is the sad history of codes) resulting in layers of nonuniform, and in many cases, irrelevant requirements. The whole purpose of my rambling remarks was to give you a little background to my asking NCSBCS to adopt the resolution which is presented in the Conference brochure. I will not read it; but in essence, it recognizes that there is an energy crisis, also recognizing the fact that NCSBCS is for promoting reciprocal, uniform code requirements, and that before the situation gets out of hand that they (NCSBCS), request the National Bureau of Standards to assist them in developing a national standard that deals with energy design of buildings. Once accomplished, a regulatory agency could reference to it in the traditional manner, (as they presently do for concrete design or steel design and other areas of building code referencing). The "S" and "E" Committee will be meeting tonight, hopefully to develop a mechanism for a uniform approach to this very critical problem. Critical in that (a) it will not solve the immediate crisis because it only addresses itself to new buildings, (b) because of an apparent ground swell by the States for using the codes to regulate energy related building design, and (c) because all of us recognize that if we do something now, certainly a significant energy savings can be realized several years hence. I think we can afford an investment of one or one and one-half years to do the job properly. Thank you for your patience, I hope you have the message. (A question and answer period followed.) POSTSCRIPT The Standards and Evaluation Committee of the National Conference of States on Building Codes and Standards (NCSBCS), met the evening of June 19, 1973, following the Joint Energy Workshop to consider followup action. The major result of this meeting was the recommendation that a request for the development of a draft standard for energy conservation in new buildings be made to the National Bureau of Standards (NBS) from the Executive Committee of NCSBCS. NCSBCS National Chairman Bernard Cabelus of Connecticut conveyed this request by letter to Dr. Roberts, NBS Director, on July 12, 1973. Dr. Roberts responded favorably to the NCSBCS request and assured NCSBCS that NBS would undertake the drafting of a performance standard as soon as staff could be reassigned. Work commenced in early September 1973. The staff task force was augmented by an advisory group from NCSBCS, the American Institute of Architects (AIA), the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), and the American Consulting Engineers Council (ACEC). On November 12 and 13, 1973, a Joint Workshop on Energy Standards for Conservation in Building Design was held in Washington, D. C., to assess the approach being taken in development of and to receive technical comment on the draft standard. One of the results of this Workshop was an awareness on the part of State officials that a performance-type building energy standard could not stand on its own in the regulatory environment. NCSBCS Z National Chairman Cabelus requested assistance from NBS in implementing the standard in a letter dated November 19, 1973. During a debriefing following the November Workshop, Assistant Secretary of Commerce for Science and Technology, Dr. Ancker-Johnson, directed the NBS to provide assistance in identifying the activities needed to complement the energy standard and = means for their accomplishment. On February 27, 1974, both the energy document and the description of implementing tasks were presented to NCSBCS in Salt Lake City, Utah. The NCSBCS turned the energy performance criteria over to ASHRAE for processing to become an American National Standard. The ASHRAE 90-P draft standard was available for public comment in late June 1974, with a review period extending to September 30, 1974. A second ASHRAE draft was available in early 1975, with the review period ending February 28, 1975. Committee review of the comments is taking place with final availability of the ASHRAE Standard expected by the summer of 1975. The Funds needed to pursue the assemblage of tasks needing accomplishment now identified as a "delivery system, were requested from the Federal Energy Administration. NCSBCS organization has strongly presented the necessity for the proper implementation of such a far-reaching standard. |