ASHRAE 189.1 Addendum Reflects ‘Bunker Mentality’

Rich Walker, American Architectural Manufacturers Association
August 15, 2013
COLUMN : Industry Watch | Codes & Standards

While this column is generally devoted to happenings in the residential fenestration industry, there have been some negative developments in the commercial energy code arena in recent years that deserve everyone’s attention. In 2010, the fenestration industry successfully blocked a proposal to amend ASHRAE 90.1, Energy Standard for Buildings Except Low-Rise Residential Buildings, to reduce the maximum permitted glazing area allowed in the prescriptive path by 25 percent, from 40 percent window-to-wall ratio to 30 percent. If those numbers sound familiar, it’s because they have resurfaced in the form of a proposed new addendum to ASHRAE 189.1, Standard for the Design of High-Performance Green Buildings, which would apply the same restrictions to buildings with less than 25,000 square feet of conditioned space.

The ASHRAE 189.1 workgroup 7 on Energy Efficiency met June 25 to discuss the reported 72 public comments received from 57 different entities during the 45-day public review period, May 3 through June 17. Each and every one of these comments was negative and asked for withdrawal of the proposal.

There were the expected thumbsdown critiques from industry stakeholders. AAMA, for example, weighed in with the comment that “[The requirement] should stay as it is in 189.1. ... Higher emphasis should be placed on daylighting, ventilation, orientation and psychological benefits. [The proposed addendum] also places unjustified burdens and restrictions on the architect/designer.” Notably, there were also negative comments from architects, university professors, building officials, lighting designers, daylighting researchers and even one of the co-authors of the study ASHRAE is citing as justification for the proposal.

This level of controversy bears witness to the gravity of this issue. Indeed, a lot is at stake. According to industry consultant Dr. Thomas Culp, owner of Birch Point Consulting LLC, more than 75 percent of all buildings—a third of all floor space—is less than 25,000 square feet, meaning this proposal would have a major impact on green building design for schools, offices and assisted care facilities. To comply with the reduced WWR, we would likely see fewer windows, shorter/smaller windows, a transition from strip windows to punched openings, and a transition from curtain wall to strip windows, Culp says.

ASHRAE’s proposal harkens back to the bunker mentality of the 1970s, when windows were viewed ipso facto as energy drains and architects replaced natural light with artificial light wherever possible. The current prevailing green wisdom, however, is that any approach that treats an opening in the building envelope as having a negative impact on energy efficiency ignores the benefits of such openings to the energy balance of the building and the well-being of its occupants.

Obviously, daylighting is an energy-saving measure by virtue of reducing the energy demand for electric lighting and the heat load that electric lighting places on air conditioning systems. But in addition, studies comparing buildings with optimized daylighting systems to those without come to the same conclusions: People simply perform better in a daylit environment. In general, they show greater and faster mental activity and decisionmaking. In retail settings, increased sales and more transactions result. Patients heal faster in daylit healthcare facilities.

Daylight harvesting thus fits well within the green paradigm that all building components must work together interactively to optimize overall energy use, environmental impact and occupant welfare. It is therefore particularly disconcerting that the proposed addendum goes against the published goal of ASHRAE 189.1, which states, “The purpose of this standard is to provide minimum requirements for … high performance, green buildings to … balance environmental responsibility, resource efficiency, occupant comfort and well being, and community sensitivity.” The addendum is not true to the holistic green philosophy that the standard purports to serve, not to mention conflicting with LEED and other green standards.

The ASHRAE 189.1 workgroup took no formal action on June 25 other than to form a task group to discuss the proposal and comments at a later time. If appeals from the industry are not successful, the addendum will have a final presentation and a vote for publication late this fall. Then, there might be a final opportunity for appeal in 2014. We will be well advised to pay close attention and participate.

Rich Walker is president and CEO of the American Architectural Manufacturers Association, 847/303-5664,