Alison,

Please accept these comments on on Docket ID number OPPT--2004--0092
Draft Federal Guide for Green Construction Specs. Thank you for the
opportunity to comment.

Andy Walker PhD PE

Senior Engineer

National Renewable Energy Laboratory

1617 Cole Blvd

Golden CO 80401-3393

phone (303) 384-7531

fax (303) 384-7411

email [andy_walker@nrel.gov]{.underline}

01100

Consider adding to 1.3.A \"The goal is to produce a beautiful,
sustainable, cost-effective building that meets the building\'s
functional program, encourages productivity, and consumes as few
non-renewable resources as possible.\"

1.3.A.1.e

suggest replacing \"DfE methodologies\" with \"sustainable design
principles\" or link to a source of information that describes DfE more
adequately than the definitions section.

suggest adding to 1.3.A.f \"minimize life cycle energy cost through a
package of features including daylighting, passive solar heating and
cooling, energy efficiency, and renewable energy resources such as solar
water heating and photovoltaics\"

1.3.A.2 comfort is mis-spelled.

1.3.B.3 \"EPA Energy Star: Provide **\[final structure in compliance\]
\[work consistent\]** with EPA Energy Star label requirements.\" is not
clear. Energy star does not have label requirements, other than the
eligibility requirements which are not controlled by the designer. At
this location you could require that the design team set an Energy Star
goal using EPA Energy Star Targetfinder.

01300

suggest adding 3.A \"Prepare and submit package of documentation
required by US GBC for official LEED certification. Respond to requests
for answers to questions and other information from USGBC to complete
the LEED certification process.\"

suggest adding 3.B \"Contractor shall evaluate progress toward goals set
in 01100 including LEED rating and other goals and coordinate the
creation of a building design that meets the goals. Contractor shall
integrate the work of different disciplines to achieve effective
daylighting and other features requiring inter-disciplinary
coordination.\"

02220

suggest adding to 3.A \"inspect and evaluate for re-use any existing
structures on site\"

02230

to 1.2.E add \"Landscape designer shall minimize paved areas and
preserve or restore native vegetation.\"

add a C.3: \"Develop and utilize an erosion control plan\" add erosion
control plan to approved submittals.\"

02780

add \"rainwater catchment systems\"

02900

suggest adding to 1.1: \"Design landscape to reduce building energy use
by siting and planting to provide shade or sun as required to improve
performance and to mitigate or enhance natural ventilation to improve
performance.\"

suggesting adding 2.5.A \"evaluate and optimize measures to reduce water
use in the landscape. Optimize efficiency of any irrigation systems.\"

03300

add to specifyer note: \"Integrate the need to withstand physical forces
with sustainability requirements, including the size and location of
window openings, required clear spans for daylighting, and the exchange
of heat with themal mass.\" and also add \"Inspect and evaluate for
re-use any existing concrete structures on site.\"

04200

add to specifer note: \"Integrate the structural and visual needs of the
masonry with sustainability requirements, including interior colors
required for daylighting goal and the exchange of heat with themal
mass.\" and also add \"Inspect and evaluate for re-use any existing
masonry structures on site.\"

06070

add to specifier note: \"Do not specify wood furnishings or finishes
that require tight humidity controls of the mechanical systems. Comfort
standards allow humidity to fluctuate to save energy costs.\"

07200

add to specifier note: \"Optimal thickness the insulation is determined
by minimizing life cycle cost.\"

07500

add to specifier note: \"FEMP maintains recommendations for roofing
materials at
[http://www.eere.energy.gov/femp/technologies/eep_roof_products.cfm]{.underline}\"

08500

add to specifier note: \"Window properties are critical to energy
performance and visual satisfaction. Specify low U value to reduce
winter heat loss and summer heat gain. Windows on the west and east
sides experience maximum solar gain in summer and should have a low
Solar Heat Gain Coefficient (SHGC). Low SHGC is achieved with selective
glass, tinted glass, or reflective coating. Specify selective glass for
clear appearance or when high visible transmittance is required for
daylighting goals. South side glass may be protected from summer sun by
an overhang and have a high SHGC if winter heat is useful. Specify a low
SHGC for south-side glass if the building is dominated by internal heat
gain and solar heat is unwelcome even in winter. North side recieves
very little sun and requires no special treatment. FEMP maintains a
guide on residential window recommendations at
[http://www.eere.energy.gov/femp/technologies/eep_res_windows.cfm]{.underline}\"

08500 2.3.A.1.d

add \"d.visible transmittance

e\. exterior reflectivity

f\. color of tint, if any\"

10400

add to specifer note: \"Specify low power LED illuminated signage for
exit signs and lit directional signage. Consider photovoltaic power for
illuminated signage removed from a building electrical panel by distance
or obstructions.\"

11450

add to specifier note: \"FEMP maintains product efficiency
recommendations for a wide range of residential equipment including
appliances and mechanical equipment at
[http://www.eere.energy.gov/femp/technologies/eep_eerecommendations.cfm]{.underline}.\"

11680

add to specifier note: \"FEMP maintains product efficiency
recommendations for a wide range of commercial equipment including
office equipment, appliances and mechanical equipment at
[http://www.eere.energy.gov/femp/technologies/eep_eerecommendations.cfm]{.underline}.\"

12100 and 12700

add to specifyer note: \"Do not specify artwork or furnishings that
require tight humidity controls of the mechanical systems. Comfort
standards allow humidity to fluctuate to save energy costs.\"

**re-written SECTION 13600 -- RENEWABLE ENERGY SYSTEMS**

SPECIFIER NOTE:

*resource management:* Having reduced the load by taking all the energy
efficiency measures that are cost-effective for a project, providing the
energy required by clean, renewable resources is more sustainable than
fossil fuels which are finite is supply and incur environmental impacts
of air emissions. The Federal Energy Management Program (FEMP) provides
information on technologies that have been proven in field testing or
recommended by reliable sources. The Energy Policy Act of 1992 and
Executive Order 13123 set goals for energy reduction and provide some
guidelines for implementing conservation and renewable energy measures.
Annual energy use in Federal buildings has dropped from 140,000 Btu/sq
ft (1,600 MJ/m2) in 1985 to 116,000 Btu/ sq ft (1,300 MJ/m2) in 1997. To
meet the Executive Order 13123 requirement, annual energy use must drop
to 90,800 Btu/sq ft (1,000 MJ/m2) by 2010." The Executive Order also
directs agencies to significantly increase the use of renewable energy
and to install 20,000 solar energy systems by 2010. Agencies have set a
goal of 2.5% of Federal energy use from renewables by 2010 from green
power purchases, on-site renewable energy projects, or other projects
developed on Fedreral land. Refer to "Greening Federal Facilities: An
Energy, Environmental, and Economic Resource Guide for Federal Facility
Managers and Designers\"
[http://www.eere.energy.gov/femp/pdfs/29267-0.pdf]{.underline} for
technology descriptions. Renewables are characterized by a high initial
cost and low operating cost, and are often designed to minimize life
cycle cost.

*toxicity/IEQ:* Some renewable energy technologies such as photovoltaics
are available to generate power on-site with no toxics or emissions.
Non-toxic alternatives shall be specified for all system components
where available, such as food-grade propylene glycol as the heat
transfer fluid in solar water heating systems. Electric renewables
systems include battery storage if off-grid, and safeguards shall be
taken while installing and maintaining the electrolyte and batteries
shall be properly recycled at the end of their useful life. While there
are well-known concerns regarding the toxic components of batteries,
overall the systems that utilize renewable energy sources are generally
considered to be less hazardous to human health and environmental health
because they do not involve the combustion of a fossil fuel..

*performance:* This is a rapidly changing field. DOE -- Energy
Efficiency and Renewable Energy (EERE) and the National Renewable Energy
Laboratory (NREL) offer resources for renewable energy, green power, and
high performance buildings. Refer to [http://www.nrel.gov/]{.underline}
and to [http://www.eere.energy.gov]{.underline}

> \- Daylighting is perhaps the principle opportunity for renewable
> energy use in Federal buildings. A daylit building includes apertures
> to admit and distribute natural light, measures to control glare and
> backlighting, and a control system to realize savings by dimming or
> switching electric lighting circuits.
>
> \- Passive solar heating is an important strategy in
> envelope-dominated buildings but in buildings dominated by internal
> heat gains the problem of avoiding solar heat gain can be equally
> important. Care must be taken to avoid local discomfort due to solar
> glare and heat gain in each and every workspace.

\- Photovoltaic, or PV, cells are semiconductor devices that convert
sunlight into electricity. They have no moving parts. While expensive,
they are expected to have very long lifetimes (25 years) with little or
no maintenance. PV products are often integrated into building materials
such as standing seam metal roofing, window or overhead glazing, or
shingles. While PV is often deployed on buildings connected to the
utility, they have a higher value in remote locations where they
displace more expensive and more-polluting diesel generators. Energy
storage in remote applications, if needed, is provided with batteries.
The US EPA has developed a [solar environmental benefits
calculator]{.underline} which computes, based on the amount of
electricity produced by a PV system and the geographic location of that
system, the amount of nitrogen oxide (NOx), sulfur dioxide (SO2), and
carbon dioxide (CO2) that is prevented from being emitted each year.

\- Wind turbines range in capacity from small turbines---500 watts to
100 kW--- to large, utility-scale turbines---250 kW to 3.5 MW. Over the
past 20 years, the cost of producing wind energy has come down from
approximately 40 cents per kWh to approximately 3 to 5 cents per kWh for
bulk power. NREL's National Wind Technology Center researchers predict
that near-future design improvements will lower production costs to as
little as 2.5 cents per kWh, making wind energy cost-competitive with
conventional fuels.

\- Fuel cells generate electricity by converting chemical energy into
electrical power with few moving parts. Fuel cells produce no noxious
gases that produce acid rain, no particulate pollutants, no unburned
hydrocarbons, and proportionately less carbon dioxide (CO2) than other,
less efficient technologies. The U.S. Department of Energy has launched
a major initiative, the \"Solid State Energy Conversion Alliance\", to
bring about dramatic reductions in fuel cell costs. The goal is to cut
costs to as low as \$400/kW by 2010. It should be pointed out that fuel
cells utilize hydrogen fuel, often derived by reforming natural gas, and
thus are not renewable energy sources. However, due to their reduced
emissions, they will be favored over heat engines as they become cost
effective and reliable.

\- Energy can be derived from biomass by burning it directly, by
converting it into energy-rich gases (gasification) that can fuel
advanced gas turbines or fuel cells, and by converting it into liquid
fuels (biofuels) that can fuel vehicles and other power-supply
equipment. Executive Order 13134, creating a national Biobased Products
and Bioenergy Coordination Office co-chaired by the Secretaries of the
USDA and DOE, established a goal to "triple the U.S. use of biobased
products and bioenergy by 2010. Biomass power systems range in size from
a few kW (enough for an average U.S. home) up to 80 MW for power plants.
In today's "direct-fired" biomass power plants, generation costs are
about \$0.09/kWh. DOE estimates that future, advanced technologies such
as gasification-based systems could generate power for as little as
\$0.05/kWh.

\- Combined heat and power, or CHP, is the joint production of both heat
(usually steam or hot water) and electricity from a single fuel source.
Conventional U.S. power production converts roughly one-third of the Btu
from the primary energy source (e.g., coal or natural gas) into
electricity; most of the rest is lost as waste heat. Collecting and
making productive use of that waste heat can result in total
efficiencies over 70 percent. Combined heat and power is often referred
to as cogeneration. Technologies for cogeneration include gas turbines,
steam turbines, and reciprocating engines.

Other options for renewable energy include contracting for "green power"
generated and supplied by a utility. Buying green power contributes to
the renewable energy goal of EO13123 and encourages utilities to invest
in these promising resources. th deregulation of the electric utilities,
many new procurement options are becoming available, including the
possibility of buying green energy from nonpolluting, renewable sources.
While many utilities charge a premium for green power, a trend is for
regulators to require utilities to include wind power in their resource
planning without a premium because it is not more expensive that
conventional plants.

PART 1 GENERAL

1.1 SUMMARY

> A. Section Includes:
>
> 1\. Solar Energy System(s).
>
> 2\. Wind Energy System(s).
>
> 3\. Biomass Energy Systems(s)
>
> 4\. Green Power.
>
> 5\. **\[xxxx\]**.

1.2 SUBMITTALS

> A. Product data. Unless otherwise indicated, submit the following for
> each type of product provided under work of this Section:

SPECIFIER NOTE:

Specifying local materials can help minimize transportation impacts.
Transportation impacts include: fossil fuel consumption, air pollution,
and labor. USGBC-LEED™ v2.1 includes credits for materials harvested and
manufactured within a 500 mile radius from the project site.

> 1\. Local/Regional Materials:
>
> a\. Indicate location of manufacturing facility; indicate distance
> between manufacturing facility and the project site.
>
> b\. Indicate location of extraction, harvesting, and recovery;
> indicate distance between extraction, harvesting, and recovery and the
> project site.

SPECIFIER NOTE:

USGBC-LEED™ v2.0/2.1 include credit for using on-site renewable energy
for minimum 5 percent of the building's total energy. Credit is also
offered for green power contracting. The contract must provide minimum
2-years of renewable energy for a minimum 50 percent of the building's
total energy.

FEMP references green power as per the Center for Resource Solutions
Green-e program. USGBC-LEED™ v2.0/2.1 also cites the Center for Resource
Solutions Green-e program. Refer to
[http://www.green-e.org/]{.underline}

> 2\. Renewable Energy:
>
> a\. Submit manufacturer's product data for system, including rated
> capacity and certifications.
>
> b\. Submit calculations indicating the energy produced by the system
> relative to the total energy demand for the building.
>
> c\. Submit Letter of Certification from system provider indicating
> that energy produced by the system represents minimum **\[5\] \[10\]
> \[20\] \[50\] \[xxxx\]** of the total energy demand for the building.
>
> d\. Submit copy of certification for Green Power in accordance with
> the Center for Resource Solutions Green-e Standard for Electricity
> Products. Indicate type and percentage mix of renewable energy
> provided.
>
> B. Submit environmental data in accordance with Table 1 of ASTM E2129
> for products provided under work of this Section.

1.3 QUALITY ASSURANCE

SPECIFIER NOTE:

Decisions as to appropriateness of system requirements and design are
dependent upon project goals and location. Different code-making
organizations promulgate numerous requirements for photovoltaic panels.
PowerMark Corporation administers a product certification process that
is both nationally and internationally accepted. There are certification
programs covering PV modules, components, and packaged systems. PMC is
the sole U.S. agent for the Global Approval Program for PV (PV-GAP) and
the only U.S. PV testing and certification program meeting the
requirements for international reciprocity. These standards are
compatible with International Electrotechnical Committee (IEC)
standards.

For solar water heating systems, the Solar Rating and Certification
Corporation (SRCC) rates both collectors and entire systems.

> A. Solar Energy Systems:

1\. Submit compliance with the following codes and standards.
Photovoltaic Panels shall carry the PowerMark certification by PowerMark
Corporation, a requirements which encompasses specific standards
promulgated by other organizations. Nearly 100 standards regarding solar
energy systems are promulgated by American Society for Testing and
Materials (ASTM) 100 Barr Harbor Drive West Conshohocken, PA 19428
Phone: (610) 832-9585; Fax: (610) 832-9555 Email:
[service@astm.org]{.underline} World Wide Web:
[http://www.astm.org/]{.underline}. These include mechanical and
electrical integrity of the module under impacts, pressure and thermal
cycling. The Institute of Electrical and Electronic Engineers, Inc 345
East 47th Street New York, NY 10017, USA promulgates standards for
electrical and electronic equipment, most notably; **P929 Recommended
Practice for Utility Interface of Photovoltaic (PV) Systems**
[(specifying]{.underline} requency and voltage limits, power quality,
and non-islanding inverter testing). Underwriters laboratory 333
Pfingsten Road Northbrook, IL 60062 promulgates standards for Electrical
Equipment Safety for manufacturers, most notably **UL Standard 1703,
Flat-plate Photovoltaic Modules and Panels and UL Standard 1741,
Standard for Static Inverters and Charge Controllers for Use in
Photovoltaic Power Systems** [which]{.underline} incorporates the
testing required by IEEE 929 and includes design (type) testing and
production testing.

The National Electrical Code (NEC) includes requirements for all
renewable energy installations for electrical trades and industry
experts. Article 690 includes special information for Solar Photovoltaic
Systems and requires UL listing for utility interface inverters. Other
sections (Article 230, 240, 250 and 300 to 384 include requirements for
wiring and overcurrent protection. A good resource is
http://www.nmsu.edu/\~tdi/codes&.htm

n

For Solar Water Heating collectors submit OG 100 rating by Solar Rating
and Certification Corporation for collector performance characteristics,
and for rated systems submit OG 300 rating.

> B. Wind Energy Systems:

SPECIFIER NOTE:

The American Wind Energy Association (AWEA) has worked to develop wind
industry consensus standards in partnership with the U.S. Department of
Energy and other organizations. These standards, currently in
development, are intended to be compatible with International
Electrotechnical Committee (IEC) standards to ensure that U.S. wind
businesses have full access to foreign markets.

> 1\. Performance:
>
> IEC 1400-1: Safety Requirements for Large Wind Turbines
>
> IEC 1400-2: Small Wind Turbine Systems
>
> IEC 1400-11: Acoustic Emission Measurement Techniques
>
> IEC 1400-12: Performance Measurement Techniques
>
> C. Biomass Energy Systems:
>
> 1\. Performance:
>
> ASTM E1758- Standard Test Method for Determination of Carbohydrates in
> Biomass by High Performance Liquid Chromatography
>
> ASTM E1821- Standard Test Method for Determination of Carbohydrates in
> Biomass by Gas Chromatography
>
> ASTM E1721- Standard Test Method for Determination of Acid-Insoluble
> Residue in Biomass
>
> ASTM E1755- Standard Test Method for Ash in Biomass
>
> ASTM E1690- Standard Test Method for Determination of Ethanol
> Extractives in Biomass
>
> D. Green Power: Comply with renewable energy requirements in
> accordance with the Center for Resource Solutions (CRS) Green-e
> Standard for Electricity Products.

1.4 MAINTENANCE

> A. Green Power: Provide service contract for **\[2\] \[xxxx\]** years
> with options for annual renewal thereafter.
>
> 1\. Comply with the Center for Resource Solutions (CRS) Green-e
> Standard for Electricity Products for the duration of the contract.
> Comply with requirements of the CRS Green-e Annual Verification
> Protocol.
>
> a\. Immediately notify Owner if electricity product fails to comply
> with Green-e certification criteria during contract period.
>
> 2\. On an annual basis for during contract period, submit:
>
> a\. Annual report that includes data on the resources used to generate
> the past year's electricity purchased.
>
> b\. Disclosure statement lists the resources or fuel sources from
> which the electricity in the product will be generated in the
> following year.

PART 2 PRODUCTS

2.1 EQUIPMENT

SPECIFIER NOTE:

Decisions as to appropriateness of system requirements and design are
dependent upon project goals and location. Coordinate with Divisions 15
and 16.

PART 3 - EXECUTION

3.X SITE ENVIRONMENTAL PROCEDURES

> A. Resource Management:
>
> 1\. Energy Efficiency: Verify equipment is properly installed,
> connected, and adjusted. Verify that equipment is operating as
> specified.
>
> 2\. Renewable Energy:
>
> a\. Verify proper operation in all modes of system operation by
> testing. Verify proper operation under a wide range of conditions to
> verify energy delivery as calculated for those conditions. Solar
> Energy Systems: Comply with ASTM E1799- Standard Practice for Visual
> Inspections of Photovoltaic Modules.

END OF SECTION

015800

add to specifier note: \"Evaluate natural ventilation for appropriate
spaces, and design air distribution systems to operate in the same
direction as natural ventilation to reduce energy cost of pumping
outdoor air.\"

16200

1.2.A.2.c. add \"lumens per watt efficiency of light source; color
rendition index of light source\"