U.S. DEPARTMENT OF COMMERCE / National Bureau of Standards

Research and Innovation

in the

Building Regulatory Process

c.2
NATIONAL BUREAU OF STANDARDS

The National Bureau of Standards' was established by an act of Congress March 3, 1901. The

Bureau's overall goal is to strengthen and advance the Nation's science and technology and

facilitate their effective application for public benefit. To this end, the Bureau conducts

research and provides: (1) a basis for the Nation's physical measurement system, (2) scientific and technological services for industry and government, (3) a technical basis for equity in trade, and (4) technical services to promote public safety. The Bureau's technical work is performed by the National Measurement Laboratory, the National Engineering Laboratory,

and the Institute for Computer Sciences and Technology.

THE NATIONAL MEASUREMENT LABORATORY provides the national system of

physical and chemical and materials measurement; coordinates the system with measurement

systems of other nations and furnishes essential services leading to accurate and uniform

physical and chemical measurement throughout the Nation's scientific community, industry,

and commerce; conducts materials research leading to improved methods of measurement,

standards, and data on the properties of materials needed by industry, commerce, educational

institutions, and Government; provides advisory and research services to other Government

Agencies; develops, produces, and distributes Standard Reference Materials; and provides

calibration services. The Laboratory consists of the following centers:

Absolute Physical Quantities^ — Radiation Research — Thermodynamics and

Molecular Science — Analytical Chemistry — Materials Science. THE NATIONAL ENGINEERING LABORATORY provides technology and technical

services to users in the public and private sectors to address national needs and to solve national problems in the public interest; conducts research in engineering and applied science

in support of objectives in these efforts; builds and maintains competence in the necessary

disciplines required to carry out this research and technical service; develops engineering data and measurement capabilities; provides engineering measurement traceability services; develops test methods and proposes engineering standards and code changes; develops and

proposes new engineering practices; and develops and improves mechanisms to transfer

results of its research to the utlimate user. The Laboratory consists of the following centers:

Applied Mathematics — Electronics and Electrical Engineering' — Mechanical

Engineering and Process Technology- — Building Technology — Fire Research —

Consumer Product Technology — Field Methods.

THE INSTITUTE FOR COMPUTER SCIENCES AND TECHNOLOGY conducts

research and provides scientific and technical services to aid Federal Agencies in the selection, acquisition, application, and use of computer technology to improve effectiveness and

economy in Government operations in accordance with Public Law 89-306 (40 U.S.C. 759), relevant Executive Orders, and other directives; carries out this mission by managing the Federal Information Processing Standards Program, developing Federal ADP standards

guidelines, and managing Federal participation in ADP voluntary standardization activities; provides scientific and technological advisory services and assistance to Federal Agencies; and

provides the technical foundation for computer-related policies of the Federal Government.

The Institute consists of the following divisions:

Systems and Software — Computer Systems Engineering — Information Technology.

'Headquarters and Laboratories at Gaithersburg, Maryland, unless otherwise noted; mailing address Washington, D.C. 20234. Some divisions within the center are located at Boulder, Colorado, 80303.

The National Bureau of Standards was reorganized, effective April 9, 1978.
NATIONAL B DREAD

OF STANDAiiDS LIBRARY Research and Innovation in the

Building Regulatory Process

AUG 2 3 1978

Proceedings of the Second

NBS/NCSBCS Joint Conference

Held in Bozeman, Montana on

September 20, 1977, in conjunction

with the Tenth Annual Meeting of the

National Conference of States on Building

Codes and Standards, Inc. (NCSBCS)

Patrick W. Cooke, Editor

Building Economics and Regulatory Technology Division

Center for Building Technology

National Engineering Laboratory

National Bureau of Standards

Washington, D.C. 20234

Sponsored by

U.S. Department of Commerce

National Bureau of Standards, and

National Conference of States on

Building Codes and Standards (NCSBCS).

U.S. DEPARTMENT OF COMMERCE, Juanita M. Kreps, Secretary

Dr. Sidney Harman, Under Secretary

Jordan J. Baruch, Assistant Secretary for Science and Technology

Ij.^' NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director

A « »

Issued August 197$
Library of Congress Catalog Card Number: 78-600063

National Bureau of Standards Special Publication 518

Nat. Bur. Stand. (U.S.), Spec. Publ. 518, 406 pages (Aug. 1978) CODEN: XNBSAV

U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON: 1978

For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402

Stock No. 003-003-01960 Price $6

(Add 25 percent additional for other than U.S. mailing).
PREFACE

The building regulatory process in the United States is an extremely

important extension of public policy since it is the prime vehicle for

regulating safety and health in and around buildings. This process of

regulating building construction and occupancy, however, is as diverse

and dispersed as the industrial enterprise it is authorized to regulate

in the public interest.

In order to stimulate a sustained effort in establishing the basis

for a more systematic understanding of the building regulatory process

and to further identify the relationship between regulation and technical

innovation, the National Conference of States on Building Codes and Standards

Inc. (NCSBCS) and the National Bureau of Standards collaborated in the joint

sponsorship of this second national conference on research and innovation in

the building regulatory process. The Conference was held on September 20, 1977,

in conjunction with the Tenth Annual Meeting of NCSBCS in Bozeman, Montana.

The first such Conference was conducted in 1976 in Providence, Rhode Island,

and was reported on in NBS Special Publication 473*. The results of that

event were well received by both the building community and the research

community.

This document contains the twenty five papers presented at the various

technical sessions held during the second national conference on research

and innovation in the building regulatory process. The program for the

conduct of the Conference corresponds to the Table of Contents of these

Proceedings. It is hoped that occasions of this type will continue to

inform and assist understanding and decision making in the regulatory area.

*NBS Special Publication 473, "Research and Innovation in the Building

Regulatory Process," available from Superintendent of Documents, U.S. Government

Printing Office, Washington, D.C. 20402. Order No. SN003-003-01775-2

,

Price $6.00.

iil
ACKNOWLEDGEMENTS

The editor acknowledges the cooperation and assistance of the following

National Conference of States on Building Codes and Standards, Inc. (NCSBCS)

State Delegates and members of the National Bureau of Standards (NBS) Staff

who served as moderators for the technical sessions:

NCSBCS Delegates

Mr. Willard E. Bryant (Maryland)

Mr. Trevor Jacobson (Oregon)

Mr. Donald T. MacRae (Indiana)

Mr. Norman R. Osterby (Minnesota)

Mr. John Wenning (Wisconsin)

NBS Staff

Mr. James M. Hicks, Jr. (now affiliated with

the National Academy of Code Administration)

Mr. Charles T. Mahaffey

Special recognition and appreciation are extended to Ms. Rita Whalen and

Mrs. Mary Chaney of NBS for successfully coordinating the publication of these

Proceedings

.

iv
CONTENTS

Page

PREFACE iii

ACKNOWLEDGEMENTS iv

SI CONVERSION UNITS viii

ABSTRACT ix

SESSION lA, IMPLEMENTATION OF SOLAR AND ENERGY CONSERVATION

BUILDING STANDARDS

"The National Solar Heating and Cooling Information Center:

Meeting the Code Officials' Information Needs"

by Gerald Mara 1

"Implementation of Energy Conservation Building Standards"

by Thomas B . Brown 9

"A Proposal for the Implementation of Energy Conservation

Building Standards and Codes"

by John R. Groves, Jr. 17

SESSION IB, ISSUES IN BUILDING REGULATION

"Research on Natural and Man-made Hazards: Impacts on Building Regulations"

by Daniel L. Schodek 25

"Response to Building Innovation by Building Codes

and Regulations"

by Steven Winter ..... 49

"A Consulting Engineer's View of Building Code Process from

Conception to Adoption"

by Norman J. Kornsand 67

SESSION 2A, CONSIDERATIONS IN THE DEVELOPMENT OF ENERGY CONSERVATION

BUILDING STANDARDS

"Standards/Codes for Energy Conservation in Lighting Design"

by Robert L. Smith 77

"The Need for a More Explicit Definition in Building Regulations

of the Internal Thermal Environment in Buildings"

by Dean R. Heerwagen 95

"Implementation of Energy Conservation Building Standards,

the Verification Problem of HVAC Systems"

by Daryl E. Tonini 135

V
CONTENTS-Continued

Page

SESSION 2B, DEVELOPING NEW APPROACHES FOR FORMULATING BUILDING

REGULATIONS

"Systematic Organization of Standards and Codes"

by James R. Harris and Richard N. Wright 145

"Consensus Standards Formulation"

by Joseph V. Tyrrell 161

"The Role of Fire Prevention and Control on Building

Construction and Regulations"

by William H. McLain 165

LUNCHEON ADDRESS:

"Building Regulation in the Twenty-First Century"

by Hans J. Milton 177

SESSION 3A, STATE EXPERIENCES IN THE DEVELOPMENT OF ENERGY

CONSERVATION BUILDING STANDARDS

"The Texas Approach to Energy Conservation Building Standards"

by Michael N. Hart 191

"The Need to Implement Energy Conservative Insulation Standards

Based on Average Energy Use Rather Than Peak Energy Use - The

New Mexico Experience"

by Wybe J. van der Meer 205

"A Study of the Effect of Existing Energy Conservation

Regulations to Assist in the Selection of More Comprehensive

Energy Conservation Standards"

by Charles H. Fafard 219

SESSION 3B, THE EXPANDING ROLE OF THE BUILDING OFFICIAL

"Rehabilitation as an Instrument in Meeting Housing Need: Can

It Really Work?"

by Jane Heron 251

"The National Fire Incident Reporting System: Some Uses of

Fire Loss Data"

by Henry Tovey 259

"Proposed Draft for Noise Control Abatement for the City of

New Orleans"

by C. Curtis Mann 285

vi
CONTENTS-Continued

Page

SESSION 4A, APPLICATION AND IMPACT OF BUILDING ENERGY CONSERVATION

STANDARDS

"Residential Energy Conservation Building Regulations and Their

Impact on the Building Process"

by Melvyn Green 297

"The Energy Conservation Code: Implementation in New Mexico"

by James 0. Dritt 313

"Impact of State Mandated Thermal Efficiency Standards on Counties"

by Sue Guenther and Archie Twitchell 323

SESSION 4B, ADMINISTRATION OF BUILDING REGULATIONS

"Regulatory Administration: A Function of Perceived Priorities,

Costs and Benefits"

by Norton S. Remmer 359

"Development of Interface Between the Regulator and the

Manufacturer's Quality Control Personnel"

by Ed Starostovic 369

"Legal Aspects of the Building Regulatory Process"

by Paul J. Moriarty • 381

LIST OF ATTENDEES 391

vii
SI Conversion Units

The following list of selected conversion factors for the most frequently used

quantities in building design and construction may be used.

INTERNATIONAL

[SI] UNIT

CUSTOMARY

UNIT APPROXIMATE OREXACT CONVERSION*

AREA

VOLUME

CAPACITY

VELOCITY, SPEED

ACCELERATION

DENSITY

FORCE

MOMENT OF FORCE , TORQUE

PRESSURE, STRESS

meter (m) millimeter (mm)

square meter (m^)

square millimeter (mm^)

cubic meter (m^)

cubic millimeter (mm^)

liter (L)

meter per second (m/s) kilometer per hour (km/h)

foot (ft) inch (in)

square yard (yd^) square foot (ft^) square inch (in^)

cubic yard (yd^) cubic foot (ft^) cubic inch (in')

gallon (gal)

foot per second (ft/s) mile per hour (mlle/h or m.p.h.)

1 ft - 0.30A8 m*

1 in - 25.4 mm*

meter per second squared (m/s^) foot per second squared (ft/s^)

metric ton (t) kilogram (kg) gram (g)

metric ton per cubic meter (t/m^) kilogram per cubic meter (kg/m^)

kilonewton (kN)

nevton (N)

kilonewton meter (kN-m) newton meter (N-m)

megapascal (MPa) kilopascal (kPa)

1 0.8361 m2

1 ft2 0.092 90m2

1 ln2 645.2 mm2

1 yd 3 0.7646 m3

1 ft3 0.02837 m3

1 in 3 16 390 mm3

1 gal 3.785 L

1 ft/i = 0.3048 m/

WORK, ENERGY , QUANTITY OF HEAT

COEFFICIENT OF HEAT TRANSFER [U-Value]

THERMAL CONDUCTIVITY [k-Value]

pascal (Pa)

kilojoule (kJ) ioule (J)

watt per square meter kelvin

[W/(m'^-K)]

watt per meter kelvin [W/(m'K)]

ton [2000 lb] pound (lb) ounce (oz)

ton per cubic yard (ton/yd')

pound per cubic foot (lb/ft')

ton-force (tonf) kip [1000 Ibf] pound-force (Ibf)

ton-force foot (tonf -ft) pound-force inch (Ibf- in)

ton-force per square inch (tonf/in^) ton-force per square foot (tonf/ft^) pound-force per square inch (Ibf/in^)

pound-force per square foot (Ibf/ft^)

British thermal unit (Btu) foot pound-force (ft-lbf)

Btu per square foot hour degree

Fahrenheit (Btu/ft^ .h. °F)

Btu per foot hour degree Fahrenheit

(Btu/ft.h.°F)

1 mile/h = 1.609 km/h

1 ft/s2 - 0.3048 m/s2*

1 ton = 0.9702 t 1 lb = 0.4536 kg

1 oz = 28.35 g

1 ton/yd3 = 1.187 t/m'

1 lb/ft3 = 16.02 kg/m3

1 tonf = 8.896 kN

1 kip = 4.448 kN

1 Ibf = 4.448 N

1 tonf. ft

1 Ibf. in -

= 2.712 kN-m

0.1130 N-m

1 tonf/in^ . 13.79 MPa

1 tonf/ft2 = 95.76 kPa

1 lbf/in2 = 6.895 kPa

1 lbf/ft2 = 47.88 Pa

1 Btu - 1.055 kJ

1 ft-lbf = 1.356 J

1 Btu/ft2.h-°F - 5.678 W/(m2.K)

1 Btu/ft-h'°F = 1.731 W/(m-K)

NOTES: (1) The above conversion factors are shown to four significant digits, where appropriate. The asterisk (*) denotes an exact conversion.

(2) Unprefixed SI units are underlined . [The kilogram, although prefixed, is an SI base unit]

(3) A more comprehensive listing of conversion factors is contained in Appendix A of NBS Technical Note 938 (pages 32 - 35).

(4) Additional conversion factors are shown in ANSI Z210.1 - 1976, "American National Standard for Metric Practice;" ASTM E380 - 76, or IEEE Std 268 - 1976.

viii
ABSTRACT

The Second NBS/NCSBCS Joint Conference on Research and Innovation in the

Building Regulatory Process was held in Bozeman, Montana on September 20, 1911.

The proceedings contain the 25 papers presented at the eight technical sessions.

The technical sessions addressed the following issues:

- Implementation of Solar and Energy Conservation Building Standards

- Issues in Building Regulations

- Considerations in the Development of Energy Conservation Building

Standards

- Developing New Approaches for Formulating Building Regulations

- State Experiences in the Development of Energy Conservation

Building Standards

- The Expanding Role of the Building Official

- Application and Impact of Building Energy Conservation Standards

- Administration of Building Regulations

ix

THE NATIONAL SOLAR HEATING AND COOLING INFORMATION

CENTER: MEETING THE CODE OFFICIALS' INFORMATION NEEDS

by

Gerald Mara

Legislative Specialist

National Solar Heating and Cooling Information Center

Rockville, Maryland

Under the provisions of the Solar Heating and Cooling

Demonstration Act of 1974, a National Solar Heating and Cooling Center

was established in 1976 by the Department of Housing and Urban

Development, in cooperation with the Department of Energy. It is the

express mission of the Center to gather information about the

practical feasibility of solar heating and cooling systems in homes

and buildings and to disseminate this information to the general

public and to specialized technical or professional groups including

building code officials.

Recent developments are accelerating code officials' need for

solar information. Solar homes are being built in all geographic

areas of the country. Architects, engineers, designers and contractors are gaining solar experience or showing an interest in solar. In

addition, many State legislatures are taking direct or indirect action

in the solar area which will affect building codes. Some States

include general or specific solar considerations in State building

codes. Others are making solar familiar by requiring life-cycle cost

estimates of competing forms of energy, including solar, in new or substantially renovated State buildings.

Key Words: Building regulations; data collection; demonstration

program; dissemination; information needs; residential

construction; solar energy; space heating; technology.

1
i

Good morning. My name is Gerald Mara and I am the governmental I affairs specialist of the National Solar Heating and Cooling Inforj mation Center. Let me begin this presentation by saying a few words i about the Center. The National Center is operated by the Franklin j Institute Research Laboratories in Philadelphia for the U.S. Department of Housing and Urban Development in cooperation with the Depart- ! ment of Energy. The Center was set up in 1976 as part of the National

Program for the Solar Heating and Cooling of Buildings. It is the

Center's job to gather information about the practical feasibility of

solar heating and cooling systems in homes and buildings, and to ! disseminate this information to the general public and to specialized

or professional groups.

| All of the specialized groups we serve have some particular ' connection with the building process. These include builders/

| developers of large housing tracts, construction or installation professionals, lenders who provide construction or home mortgage

financing, manufacturers of solar products and policy makers,

including legislators and code officials. We believe that this latter

group is of great importance and it is the Center's ability to meet

their (your) information needs that I am going to discuss today.

Before I say more about what the Center can provide to you, let me step back a bit and indicate briefly why code officials and other

policy makers are finding it increasingly necessary to get information

about solar energy.

The reason for their need is fairly simple - the increasing

construction of solar homes in the United States. Now, when I say

"solar home" in this context, I am referring chiefly to homes (or

buildings) whose space and/or domestic water heat is provided more or

less directly by solar energy. That is, I am not referring to the

conversion of solar energy to electricity, but to the direct

application of solar energy in buildings that is technically and

economically feasible on a widespread scale today.

The application of solar technology for space and domestic water

heating is certainly not new. Some domestic uses of solar have been

utilized quite literally since the dawn of civilization. But, at

least in this country, the use of solar energy for these purposes has

certainly never been more widespread than it is today.

Today solar homes are being built in all geographic areas of the

country. Let me show you some examples. These new homes with space

and domestic water heating supplied by solar were built as a part of

HUD's residential demonstration program. This next series of slides

contains pictures of solar domestic hot water installations in

northern climates. Most of these were solar retrofits or solar

additions to existing buildings. (The pictures shown on page 3

illustrate typical installations of this type)

.

There are many reasons to believe that these structures constitute

only the beginning of the use of solar in homes and buildings. The National

Center estimates that right now there are between three and five thousand

2
3
buildings in the U.S. with solar space and domestic water heating and

there are many times that number with solar heated water only. As I mentioned earlier, the Center provides information to building professionals with solar interest and experience and this number is

certainly growing rapidly. The fact is that most solar installations,

particularly hot water retrofits, can be done by applying practices

standard to existing building trades. It is getting easier to find a building professional who is willing and able to do a solar job.

Many State legislatures are also taking steps to encourage solar

construction. Currently, 28 States offer some form of tax incentive,

such as property or sales tax exemption or an income tax credit or deduction for a person who installs solar. What I have described to

you is a series of private and public commitments to increasing the

number of solar homes in this country.

Let us go back now to the slides of the solar homes you saw

earlier. These structures had to comply with State or local building

codes just like other kinds of conventional construction. Building

code officials were asked to inspect these structures and to determine if they should be approved. Of course solar homes are not really

that much different from conventional homes.

In many cases, particularly solar domestic hot water retrofits,

solar will have relatively little impact on a home's overall design.

Most of each solar home could probably be evaluated in the same way as conventionally heated buildings.

But did code officials have any difficulty in making judgments

about the solar portion of these installations? Frankly, I do not

know. If the HUD residential demonstration program is a yardstick,

there seem to be very few problems surfacing in the evaluation of

solar systems by State and local codes. But the fact is that few

building codes contain any specifically solar provisions. Those few

that do which we know of are in the so-called hurricane belt in the

Gulf States and their provisions are designed mostly to ensure that

collectors meet some sort of wind load requirement. What most

building officials have to do now is apply certain existing provisions

to solar components that are roughly analogous, for example skylights

for active collectors.

This kind of procedure might get to be cumbersome as more solar

homes are built. In addition, at least some of the State tax incentives I mentioned earlier provide that exemptible or creditable

systems have to be approved by the State or local building department.

So, I think it is obvious that code officials are going to need more information on solar applications.

That is where the Center comes in, at least in disseminating the

information as it becomes available. Our job is to make sure that

information that is available is provided to the appropriate user

groups. Of course, the Center itself generates some information,

including lists of State, local or municipal governmental actions that

are important for solar. It also gathers information that is produced

4
I

in other areas of the solar program (as well as through other means)

and disseminates it as necessary.

Let me briefly mention some kinds of information being produced

now which are of conceivable relevance to codes officials. Let us start with the demonstration projects I mentioned earlier. HUD and

DOE currently administer a series of residential and non-residential

solar demonstration projects, which are designed to furnish

information on the technical performance of solar systems; solar's

market appeal; and the relation of solar construction to existing

building practices, including codes, zoning ordinances or obtaining

home mortgage financing.

Gathering these data is essentially the job of the other

participants in the program. The American Institute of Architects'

Research Corporation and Dubin-Bloome Associates are currently

evaluating technical data on the design and performance of the systems

used.

The Real Estate Research Corporation is currently undertaking a series of surveys of those involved in the demonstration building

process. These surveys also include gathering information from

persons in the building process who chose not to become involved in

solar construction, neither building, buying nor financing. The

portion of these surveys relevant here is that which deals with codes

officials' reactions to solar construction. Results from this portion

of the survey research will help to indicate if and where problem

areas exist in codes officials' evaluation of solar construction.

Completed reports to date indicate relatively few problems encountered

in the demonstration programs. Most of these seem due to codes

officials' unfamiliarity with solar. But these problems have been

found to be relatively easily solved.

Another series of products within the overall National Program

for the Solar Heating and Cooling of Buildings are performance

criteria for solar systems and minimum property standards for solar

construction. Currently, these standards are being used to determine

the acceptability of solar applications within the demonstration

program. The Minimum Property Standards for solar space and domestic

water heating systems can also be used now to determine eligibility

for FHA mortgage guarantees.

In addition to using these standards within existing Federal

programs, it is also thought that they can be of use in assisting the

development of model codes that can be voluntarily adopted by existing

codes' jurisdictions. The National Bureau of Standards (NBS) is

cooperating closely with HUD and the Department of Energy to help

develop some model solar codes.

Now there are the elements of the National Program which are probably of the most immediate relevance for codes officials. As I mentioned earlier, it is the Center's responsibility to ensure that

this and similar information is disseminated to the appropriate

audiences

.

5
To accomplish this objective, the Center is engaged in two basic

complementary activities, responding to the requests we receive and

outreaching to important audiences or groups

.

In the response mode, information is disseminated through the

Center's telephone and mail operations. The telephone operation, a toll-free number set-up headquartered in Philadelphia, comprises seven incoming lines handled by about 20 information analysts. The lines

are open five days a week, eleven hours a day. Currently, telephone

inquiries number about 1,650 per week. Specific questions are answered either on the spot, or, if requiring research, through a special letter.

Everyone who calls the Center is sent a basic packet of

information, data specific to the individual's request, and is placed

on our mailing list, which now numbers about 140,000.

In addition to the general information package, the Center has

available several specialized bibliographies and some specific

information materials. We also have several engineers on hand to

handle technical questions.

The other arm of the response mode is the mail operation, which

handles written inquiries received at a central post office box

number. This operation works in much the same manner as the telephone

operation. Letter inquiries are currently coming in at a rate of about

1,700 per week.

The data base or source of information disseminated in the

response mode is gathered and stored in several ways. It is gathered

through some of the other parts of the program I mentioned and through

research done by the staff at the Center.

As for storage, three major information files are currently

on line in the Center's data bank. The Center has computerized

listings of manufacturers of soiar systems and components now numbering about 400; a file on public policy, listing approximately

600 pieces of governmental action, including the solar building codes

provisions which currently exist; and a solar contacts file, composed

of over 2,000 names of architects, builders, contractors, designers,

engineers, installers and energy consultants. These individuals are either experienced or interested in solar energy systems for heating

and cooling.

Each of these files is accessible in several ways. For instance,

the file on governmental activity can be accessed through the governmental level involved, the kind of action (legislation or regulations), or the specific content of the action (tax incentive,

solar access or building code)

.

In addition to this information from our own files, the Center

has access to bibliographic data stored at ERDA/TIC; survey data at

the National Bureau of Standards; and instrumented data from HUD and

DOE demonstration projects stored at NASA. This data can be retrieved

via terminals when required.

6
Several other areas of information are available at the Center in

the form of manual look-up files. One of the major files in this

category is the solar homes files, which contains pertinent

information on over 1,500 solar homes which have been identified in

the United States. While all of our information files are updated and

expanded continuously, this file is expected to grow more rapidly.

Information from this file is given out only when the home is

available for public viewing. When the home is not open as such, only

the builder's or architect's name is given out.

Other information files include an education file covering

colleges, universities and institutions which offer courses in various

aspects of solar energy. These include training courses for solar

installers; a climatological file containing information on averaged

solar radiation values, degree days, cloudy days and other climatic

data; and demonstration project files with information on HUD and DOE

financed homes and buildings. In this connection, the Center also

disseminates information on how qualified groups may apply for the HUD

and DOE grants

.

To meet the needs of several professional groups, a file of

information on testing, evaluation and standards for solar equipment

and components is currently being established. It will contain data

on organizations conducting testing, performing evaluations and

developing standards, as well as information on approved

testing/evaluation methods and adopted or recommended State, Federal

and industry-wide standards. When model codes become available, the

Center will maintain information on the applications they cover and

where to obtain copies. The Center may even have copies to distribute

as we do for other items such as the newest Intermediate Minimum

Property Standards.

In addition, the Center has a speakers bureau with biographic

information on about 275 knowledgeable individuals willing to address

both lay and professional groups on the topic of solar energy.

In the outreach or market development mode, the Center functions

to direct specific information gathered to those audiences it would

benefit most in terms of the program's overall goal. This approach is

aimed primarily at the building trade and professional categories...

contractors, code officials, developers, architects, designers,

planners, legislators, engineers, manufacturers, the financial

community, and trade and professional associations.

The reason for directing the market development effort at these

groups is to ensure that the professionals who will have to meet the

demand for solar homes will have adequate information at their hands.

The actual building of solar heated homes and buildings by these

groups will generate an even greater interest and subsequent potential

for the use of solar energy. After all, it serves no purpose to

create an interest in the potential purchases, if there is nothing

available on the market.

7
The means used in the market development approach include

exhibits, specialized documents, films, slide presentations, speakers

and educational packages. Some of these media currently exist and are

in use, while others are in the planning or development stages.

To give you an idea of our present outreach effort, I will

describe those media now in use. In constant use is a mobile solar

display van, which travels throughout the country visiting large

energy fairs, local groups such as schools and industrial plants, and

shopping centers. Similar tools used are portable displays such as working models, backdrops, and simulation models; and large booths

incorporating these models, which are sent staffed by the Center to

various trade and professional conferences and exhibitions throughout

the U.S.

Specialized documents are sometimes developed with a slant

towards the group being addressed to accompany the exhibits.

While I have described what we are doing now, I would like to add

a few words about our plans for the future. In addition to the

speakers bureau used in the response mode, the Center is beginning to

get involved in having its own staff arrange conferences, workshops

and panel discussions within the framework of a larger conference. We

have just recently completed the first of four regional solar con- ferences in Massachusetts, which we are co-sponsoring with the

Massachusetts (State) Solar Action Office. One of the prime groups we address in these conferences are code officials.

The ultimate goal of the Center is to assist in bringing the

targeted audiences of both the response and market development modes

together. For example, we would like very much to bring about a dialogue between solar installers and codes officials. In this way,

it is hoped the barriers which lie in the way of solar energy development can be abolished, and we, as a nation, can get on with the task

of effectively utilizing the economically feasible and practical

applications of solar energy to heat and cool our homes and buildings.

Thank you.

8
IMPLEMENTATION OF ENERGY CONSERVATION

BUILDING STANDARDS

by

Thomas B. Brown, AIA

Assistant Professor

Department of Architectural Engineering

The Pennsylvania State University

University Park, Pennsylvania

Codes and Standards for Energy Conservation in Buildings are currently being written and adopted by States and model code organizations. These Standards are necessary as one of the means of buying

the time required to develop alternate energy sources to continue our life style.

But codes and standards are only as effective as their

implementation. Who will enforce them in new buildings and monitor

them, in existing buildings? The logical person for this immense

task is the local building code enforcement officer, who in most

cases has neither the training nor the background to deal with the

terms and concepts involved. He must be upgraded if our nation is

to gain time to become energy self-sufficient.

This paper deals with what the code enforcement officer has to

know and how he can attain the required level of knowledge to

competently enforce energy conservation standards.

Key Words: Buildings; building code official; education level; energy

conservation; evaluations; upgrading, certification.

9
BACKGROUND

Many articles and papers have been written on the "Energy Crisis"

and many solutions have been prepared. You are probably all familiar

with the figures having heard them so often. The numbers may vary

somewhat depending on the source but energy use in the United States

is broken up into the following categories: Transportation 25.2%;

Industrial 41.2%; Commercial 14.4%; Residential 19.2%. Commercial

and residential building systems together consume over one-third of

the energy used in the United States and over half of this (about 57%)

is due to space heating and cooling. It has been estimated that energy

conservation practices can probably save 15 to 25% in existing buildings

and 35 to 50% in new construction over present rates. Because this is

such a significant amount, it is important that steps be taken to assure

these savings as soon as possible.

Energy conservation can be accomplished by designing energy saving new buildings and retrofitting old buildings. The design of new buildings is the province of the architect and engineer. To make certain the

energy designs are effective, the conservation standards based on ASHRAE

90-75 must be followed. Retrofitting or remodeling is open to just

about anyone from the student to the insulation salesman. While I am not aware of any standards for existing buildings, if we are to obtain

all the advantages of energy saving possible by retrofitting, standards

must be written. When these standards are written they will have to be

implemented

.

The thousands of cities across the country that have adopted

building codes also have Building Code Enforcement Officers who are presently charged with evaluating new construction as well as upgrading

and monitoring existing construction. I believe the local code enforcement officer to be the person to implement the Energy Conservation Standards for Buildings. He is also the logical person from whom the buildin

owner can request information or obtain advice about energy conservation

measures.

EDUCATION LEVEL REQUIRED

To be effective, the code officers must be competent to answer

questions, make evaluations, and approve drawings and specifications.

Energy consumption for heating, cooling, illumination, etc. is based

on a series of abstract ideas. It is not measured like footings and

wall thicknesses with a carpenter's rule. It cannot be read like

ratings on a ventilating fan. You cannot see a BTU of heat. The code

officer will be dealing with terms such as U-value, R, degree day,

overall thermal transfer values, temperature differences, and many

others that are probably not familiar to him.

10
If the code enforcement officer is to implement energy standards,

he must become a para-professional by taking courses to upgrade his

knowledge of buildings in this area. Such courses are presently being

given by universities, model code groups, and government bodies. In

Pennsylvania, courses sponsored jointly by the Pennsylvania State

University and the Pennsylvania Department of Community Affairs are

being offered to local officials at various locations throughout the

State. The current courses are to acquaint the code officials with

the terms and calculations used in designing and evaluating heat loss

in buildings. Future courses are needed to cover other areas of energy

use such as air-conditioning, illumination, water heating, and electrical distribution. These are the areas covered by ASHRAE Standard

90-75 which is the general guide for local energy standards. With

proper background and knowledge, the requirements can be converted

into inches of insulation, size of heating and cooling equipment,

number and type of luminaires, etc. If the enforcement officer knows

what U and R mean, he can compare the building values to required

minimum R and maximum U values. These are specification standards

in that they deal with specific maximums and minimums. This is the

type of standard that is easiest to implement, for less background

knowledge is required. The building code official can be rapidly

equipped to handle this kind of number matching if no evaluation

is involved.

But how does he handle performance standards? ASHRAE 90-75

and other standards, including BOCA Basic Energy Conservation Code,

allow a system analysis approach to building design. This means the

design can deviate from the specific design criteria of maximum and

minimum values if the designer can demonstrate that the annual energy

consumption will not be greater than it would be if he had followed

the specific criteria. They also allow a credit for use of non- depleting energy sources such as wind, solar, and geo-thermal. How

does the code official handle this? Does he accept the designer's

figures, without checking, and approve the project?

How does the code officer handle calculations that are not

covered in text book examples or that vary from the examples? Should

he be able to calculate the U-value of a well-ventilated roof assembly?

Should he know that insulation can cause problems with water vapor

and condensation and requires vapor barriers or vapor retarders? How

much should he know about permeability of construction materials?

Just how much technical knowledge should the building official

have? In addition to being able to answer questions like those just

stated, should he also be able to give advice to homeowners? I think

he is the person to do this. Literature today is full of suggestions

on how to save energy. But the homeowner needs someone to clarify the

half-statements and make recommendations on which of the many methods

are most practical or economical. The code enforcement officer should

know what types of insulation are available, their relative effectiveness, and which one is best for use in a particular location. When

the magazine articles say that air and wood are good insulators, he

should know, that compared to fiberglass and polystyrene, they are actually poor insulators. If double insulating glass is recommended,

11
the building official should have enough background in materials to warn the homeowner that inexpensive insulating glass may be poor

quality* with putty and vinyl tape seal which will probably allow

moist air to leak in between the glass panes and cause fogging and

streaking.

EVALUATING ENERGY STATEMENTS

One catch-phrase is "insulate the attic to R30." This is the

equivalent of about nine inches of fiberglass. This is fine for new

buildings when the other areas of the building have equivalent R values,

such as R19 for walls and floors. But what about existing buildings

with little or no insulation? Is R30 in the attic the most efficient

and economical application? Given the same type of construction throughout a typical one story ranch house loses over half its heat through the

roof because there is more roof surface than wall surface. But the same floor area divided into two floors can reduce the proportions to 30%

roof area and 70% wall area. Here the wall becomes more critical and

the more effective location to insulate. Also, if only one part of the

building is insulated, the other parts of the building become a larger

percentage of the total remaining heat loss. Insulating the ceiling

to R19 is easy and fairly economical. Increasing the insulation over

50% to R30 does not give the same economic return because you are now

reducing a much smaller percentage of the total loss. For example,

suppose the ceiling loss is 40% of the total. Insulating to R19 and

adding no other insulation to the building could reduce this percentage

to about 12% of the new total heat loss. Even doubling the ceiling insulation to R38 could do no more than cut the remaining ceiling loss

in half, so increased insulation always has diminishing return unless

the loss of all areas is reduced equally. A much more effective and

profitable treatment is to insulate another high loss area; after the

ceiling is about R19. Insulating the walls would be most effective

as this is a large percentage of the building envelope but this is

both difficult and expensive. Additional money would be better spent

insulating the glass areas and reducing infiltration. This means storm

windows, weather stripping, and caulking. Storm windows will cut the

loss through single glass about 50%.

The person who implements the code should be able to evaluate this

kind of information rather than using the various rules of thumb blindly.

This means a working knowledge of heat loss and heat gain theory. Acquiring this knowledge does not require a deep background in physics

and math. It only requires an interest in the subject and an opportunity to learn. If the opportunity is presented through courses and the

interest is sparked by requirements that the code official update himself, he can soon become expert enough to effectively implement the

energy standards.

CERTIFICATION

In most cases, the present building official has neither the

training nor the desire to evaluate a set of plans for energy requirements.

12
One reason for this lack of interest is that no one is requiring him to

enforce legislation, for it does not exist in most areas. So the first

step, if we are to reduce energy consumption in buildings, is to legislate standards for both new and existing buildings. The second step,

then, is to upgrade the code officer so he has the knowledge and ability

to evaluate buildings, answer requests and make decisions.

But merely offering courses is not enough. Penn State University

has been offering courses to building officials for over six years and we estimate we are reaching less than 25% of the building officials in

the State. If the local code official is to become qualified, he must

be required to attend courses and be tested to monitor his learning.

Required attendance does not guarantee learning, but it can if the code

enforcement officers are to be certified and must attain a certain level

of education. States must set up standards for certification and see

that the local building officials meet these standards. If a barber

needs a license to cut hair, the qualifications of a building code officer

should certainly be certified.

CONCLUSION

If the local code enforcement officer is not qualified, who else

can handle the job? State or Federal inspectors? They will also have

to be trained and there are very few in relation to the number of buildings in this country. Architects and engineers? Their fees will discourage

building owners from requesting their services except in the case of large

and complex buildings. A possible solution is to hire an energy conservation specialist. Very few exist and their background and salary is at a much higher level than required for energy standards implementation.

Why create a new bureaucracy when there are thousands of building code

officials who are already familiar with construction and building code

requirements? The only logical person to implement energy conservation

building standards for most existing and new construction, if the standards

are to be effective and truly save energy, is a well informed, conscientious

code official, who has gained his knowledge through upgrading courses.

Specifically, this is how Energy Conservation Building Standards can

be implemented:

1. Adopt building codes in communities and municipalities where none

exist. When codes are adopted, code enforcement officers must

be appointed.

2. Work to have Energy Conservation Standards for both new and

existing buildings adopted if none exist. This can be on a State level or a model code which contains energy standards

can be adopted locally. Only about one-half of the 2400

municipalities in Pennsylvania have building codes, or put

another way, about one-third of the population of the State is

not covered by any form of building code. Many States are probably in no better situation.

13
3. Require that code enforcement officials be certified to a certain

level of expertise. Some states already have certification programs .

4. Attend seminars on the use and interpretation of Energy Standards.

If no seminars exist in local areas, attend model code seminars

or request the State government or State university to establish

seminars. These seminars can be partially or fully funded by

Federal or State monies.

5. Give advance notice of programs so municipalities can budget to

send their code officers. Any costs not funded by Federal or State government should be financed by the municipality and the

code officer should be given time off to attend programs.

6. Convince the persons responsible for sending code officers to

seminars and workshops that upgrading is necessary and desirable.

These people are generally borough, town and city managers, many

of whom apparently see no need for this expense.

7. Suggest that the code enforcement officer take the initiative to:

a. Obtain a copy of ASHRAE Standard 90-75.

b. Read the Standard before attending seminars and list questions

to be asked.

c. Be sure to ask these questions if the seminar content does not cover them.

d. Send for other energy booklets - build up a library.

e. Keep current on new developments and products, such as water flow

restrictors for shower heads and new fluorescent lamps that provide 97% the light output of existing 40 watt lamps but only use

35 watts of electrical power.

f. Scan popular magazines for information and possible misinformation.

Know what they suggest before the homeowner asks about it.

g. Ask professionals - architects, engineers and energy specialists.

h. Contact University extension offices and industry specialists as possible information sources.

Conservation will not solve our energy problems, but adoption of codes and

standards for Energy Conservation in Buildings, and the effective implementation

of these codes by the local building code official can help this nation gain

time to become energy self-sufficient.

14
REFERENCES

1. Energy Conservation in Building Design . The American Institute of

Architects (1974).

2. ASHRAE Standard 90-75 . The American Society of Heating, Refrigerating

and Air Conditioning Engineers, Inc. (1975).

3. The BOCA Basic Energy Conservation Code. 1977 . Building Officials

and Code Administrators International, Inc.

4. Pennsylvania's Energy Conservation Policy . The Governor's Energy

Council.

5 . Our Energy Problems and Solutions . Commonwealth of Pennsylvania

(1977).

15
i
A PROPOSAL FOR THE IMPLEMENTATION OF ENERGY

CONSERVATION BUILDING STANDARDS AND CODES

by

John R. Groves, Jr.

Assistant Professor

University of Kentucky

Lexington, Kentucky

This paper deals with the mechanics of application, monitoring,

and enforcement of State adopted energy conservation standards. It

will be presumed that the administrative or legislative process has

mandated an energy code for the respective State.

The issues to be examined are: (1) the complexity of the energy

standard and its appropriateness for the (a) climatic factors of the

respective State and (b) general level and magnitude of building

construction within the State; (2) the process of educating and

informing the various design professional groups who will integrate

the code requirements into new and existing structures, on both an initial and continuing education basis; (3) the process of training

and educating the enforcing agency's personnel and the factors to

consider in first choosing the appropriate State agency; (4) the

necessity for prescriptive and performance components of the code

itself and enforcement implications; and (5) the impact of energy

standards on (a) architectural design flexibility and (b) building

costs, including "tradeoff" possibilities.

Key Words: Built environment; education and training; energy

conservation; enforcement; legislation; promulgation;

regulation; standards.

17
INTRODUCTION

Virtually everyone in this country is directly affected by the

police power of the Constitution which, among other results, has led

to the enactment of laws to protect the public and general welfare.

Zoning laySi health, safety, housing, building, and fire codes are all

examples

.

The innumerable forms of regulation stemming from Constitutional

police power authority have all attempted to affect the quality of

life with emphasis on the built environment. While the ostensible

mainstay of this collection of governmental rule-making has been

public benefit, the United States is now forced to take yet another

step in the regulatory process, but this time, not to affect the

quality of life, but to insure its very survival as we presently know

it. The necessity for energy conservation is upon us, but not yet

with us. This latter comment refers to the collective inability of

this country to meaningfully and voluntarily confront what most people

still believe is a non-existent crisis.

Many States, however, have prepared or are preparing energy

legislation and Federal regulation has already established minimum

energy standards for Federal projects. The wisdom of such action may

be characterized by some as further bureaucratic intervention.

Architects and engineers in particular are less than elated over the

prospect of another "code." However, the need for action is now no longer seriously questioned^-j'y those who are even moderately

enlightened on the subject. The task now is one of putting the

regulatory language into effect, the subject to which this paper is

addressed.

THE ENFORCEMENT PROCESS

While beginning at this point takes for granted that some body of

rules concerning energy conservation has been put into effect at the

State level, there can be little taken for granted as to the anticipated similarity which the energy codes of the several States will

ultimately have.

Climatic differences alone will account for major

dissimilarities, although after the winter just past, the people of

Portland, Maine, and Atlanta, Georgia, are probably wondering just how

much their respective climatological conditions really differ. The

major division will separate those States which are users of energy

for cooling from those States requiring energy for heating. Many

States, of course, are substantial users of both and their task of

implementation will not be made easier as a result.

Given, then, the differences that will evolve from State to

State, the following observations are offered to code administrators

and entities having responsibility for putting the code to work.

18
Initially, the selection of first echelon code enforcement

personnel, or code specialists, must be a task carefully undertaken.

Unlike the experienced carpenter or plumber who could readily adapt to

the role of building inspector, or the fireman who could be groomed

for the position of fire marshal lieutenant, the energy enforcement

specialist must be technically competent in a manner unprecedented for

code enforcement personnel. This requirement is necessitated by: (a)

the technical nature of the subject matter and the permutations of

computations that could derive from a proposed design for new

buildings, and (b) the undeniable fact that flexibility and

open-mindedness must characterize the relationship of design

professional and enforcement specialist in solving energy problems,

particularly where aesthetics and design discretion are involved.

Clearly, a code requirement is a law which requires compliance.

As any lawyer will profess, however, there is the letter of the law

and there is the spirit of the law. Sometimes strict adherence to the

former will defeat the latter. If a code requires a limitation on the

glass fenestration area of a given structure, it may be that the

architect through orientation and manipulation of interior spaces and

materials may well be able to affect a greater reduction in overall

Btu loss and stay well within the building's energy budget, than would

have been the outcome of following a rigid formula governing apparent

building envelope.

In as much as energy conservation in buildings has moved so rapidly into the forefront, great care should also be exercised in the

strict enforcement of methods and materials codes.

A somewhat dramatic statement, vis-a-vis typically encountered

code language, is made in the Model Code^for Energy Conservation in

New Building Construction , Interim Code, section 102(b), subtitled

"Alternate Materials - Method of Construction, Design or Insulating

Systems." Paraphrased, that statement gives the enforcement

specialist wide latitude in determining how energy conservation

performance standards are met. This language underscores the necessity

for competent , well qualified enforcement personnel and code

administrators

.

A word of caution to code enforcement administrators and

supervisors is appropriate here. There is often a fine line between

what is discretionary and what is arbitrary. Various doctrines of

immunity have long protected municipalities and their employees from

indiscriminate and reactionary decision making. The law has usually

said that the "ballot box" is the solution to those problems. In this era of job security and protection in the public sector, this is an out-moded defense to that change. Most architects will attest that a fire marshal whose pronouncements are at best unpredictable and at

worst mercurial is not only a source of consternation and frustration,

but is sometimes a destructive and counter productive element in the

process of making a building project feasible. This lack of

predictability, and even worse, last minute change in requirements,

can wreck a proposed project, degrade the client's estimate of the

architect or engineer, and cause the expenditure of funds from which

19
nothing results. Because the fire marshal is always cloaked in the

robe of protector, a very emotionally charged situation can result if

and when he feels it necessary to defend himself from a charge of

capricious or arbitrary behavior.

While this example may seem to overstate the point, its purpose

is to illustrate the power and authority inherent in the code

enforcement official, particularly if the applicable code contains

language such as that in section 102(b) of the Interim Code.

TRAINING ENFORCEMENT PERSONNEL

After the selection process, the next phase involves the "energy"

education of those selected. For most State entities charged with the

responsibility of energy management, whether they be the office of the

state fire marshal, the office or department of energy, or some other,

this matter of educating enforcement personnel will entail plowing new

ground. Few, if any, of the selected enforcement personnel will have

technical experience allowing them to immediately function in a com- petent manner. Depending on the particular energy code adopted, there

may or may not be training programs and laboratories available in

package form from the proponent of that code. In some instances,

programs on a national level may be available to instruct a nucleus of

personnel who would then return to their home States and become instructors for others. The point is, the instructional process

prior to and concurrent with the implementation of the code is a crucial factor. With this in mind, there is at least one other

approach to the education process worth examining.

Because both users and overseers of the code will be initially

unfamiliar with the requirements of any energy code, there will exist

a unique opportunity for^^multaneous involvement of both groups in

the educational process. It is the opinion of this writer that

great benefit can result from instructional sessions wherein

architects, engineers, code administrators, and enforcement personnel

are all participants, all discussing problems together, and all

expressing their own points of view. The catalyst for this symposium

of sorts will probably be the State energy entity, or at least the

entity charged with enforcement, where there is a division. The

sponsoring or coordinating body could, however, be the State

professional societies for architects and engineers, the State

colleges of architecture or engineering, if present, the continuing

education components of any of those groups, or the enforcing agency

itself. Those groups in the former catagories will probably be better

suited to organize and coordinate these sessions, which may be offered

as a series or as a single program repeated each year.

CONTINUING EDUCATION

The need for continuing education in the field ot energy code

enforcement is of special importance. It is a subject which the

enforcement entity must evaluate on a regular basis to insure that:

(a) design professionals are afforded the opportunity to become

knowledgeable and proficient in using the code. This information

20
should be imparted in a manner consistent with State developed policy

for administering the code, as well as the requirements of the code

itself; (b) users of the code are constantly informed of inevitable

changes, adjustments, and "fine tuning" of the code, as it is put into

practice; (c) elements of the code having ramifications concerning

design latitude and material usage, especially from the architect's

point of view, are thoroughly discussed and completely understood; and

(d) there is an ongoing discussion of the cost factors associated with

implementation of the code, such that embarrassing and sometimes fatal

(to the continuation of the project) mistakes in cost estimating are

avoided. As a final element of the initial and continuing education

process, both enforcement personnel and design professionals must be

afforded opportunities to actually inspect proper field installation

procedures where new or different techniques are called for under the

code. Classroom instruction will do much to ensure proper use of the

code. The nexus between architect or engineer and contractor on the

job site, however, remains crucial. Even the best set of drawings and

specifications requires some interpretation. Selection, installation

and placement of energy conserving materials and components will

certainly follow suite, requiring some degree of on-site review, and,

to use the term in standard American Institute of Architects (AIA)

documents, "contract administration" by the design professional.

In the area of continuing education, and again because of the

"newness" of an energy code, the necessity for a single informational

State resource center seems imperative. Certainly design professionals will have cause to use this source often. Whether for preliminary

discussion of a project in the mill or for requesting the performance

criteria of materials under consideration, the need for information

and the ability to discuss problems or proposals with an arm of the

enforcing agency is clear. Under this same heading, the informational

needs of builders, subcontractors, material suppliers and home owners

should also be considered.

PUBLIC INFORMATION

The significance of the enforcing agency's role as a source of

information for those in the construction process will increase with

time. Indeed, it will be the enforcing agency which will of necessity

have contact with and knowledge of every innovative and alternative

energy device and system put into operation. Section four of the

Interim Code refers to buildings in this category as utilizing

non-depletable energy sources.

For purposes of cross-fertilization, it will be almost incumbent

upon the enforcing agency to establish some means of recording and

disseminating the means, methods, materials and data concerning

non-depletable utilization. It is not unrealistic to expect some measure of speculation and experimentation in this area, and where

this is so, the history of those systems must be given special

documentation such that subsequent designs can benefit from the

successful precedents. This information will also be of assistance in

adjusting the language of the code to accommodate new solutions.

21
Certainly, material suppliers in the energy conservation business

will be advertising the virtues of their wares, especially in the

field of alternative energy equipment utilization. Design

professionals will be bombarded with all measure of Madison Avenue's

best, some good, some not. It will, in all probability, remain the

responsibility of the State energy code enforcement entity to

accumulate and make available objective data concerning the particular

geographical adaptation and actual efficiency of all systems utilized

within the State, under the jurisdiction of the code. Also, while not

normally part of a code enforcement agency's responsibility, but

certainly having precedent in the efforts of agricultural extension

offices, the State energy office should include careful cost

documentation as part of the collection of data.

If what is being suggested appears as a metaphorical bureaucratic

balloon slowly increasing in size and authority, consider the

following. In the preliminary description of the Kentucky Energy

Department and its mandate, the statement is made that "...this

department is in comparison extremely small in its requirements for

personnel, space, and budget. Furthermore, it has every intention of

remaining that way, utilizing the resources and capabilities of other

state governmental agencies to fulfill its charge." Thus, as will

always be the case, the responsibilities are enormous while the fiscal means become more illusive, even with the assistance of Federal

funding. None of this, of course, detracts from the overall importance

of energy conservation, which as stated earlier, boils down to a simple matter of survival of our way of life as we would hope it to

The final point to be made has to do with a rather subjective

topic, that of attitude and spirit as they relate to solving the

national problem of dwindling fuel resources. The energy office of

each State will have, in this writer's opinion, still another very

important responsibility toward the people it serves. As with the

tourist commission and office of economic development, which can be

found in one form or another in every State, the energy office will

have to adopt a public relations plan second to none. To date, most

efforts in this area have been rather superficial and something

obviously less than convincing. Many studies have been undertaken,

however, at the Federal level, and it is on this basis that the State

energy offices must build to achieve results. Architects and

engineers will need little convincing and in many instances will serve

as envoys in assisting the energy department to spread the word.

Beyond this, however, every staff member of the energy office must be

led to develop a sense of urgency and an attitude of concern and

informed enthusiasm that is a constant reminder to the public of the

seriousness of the business at hand. All this may at first sound

slightly stilted. Considering the mission, however, and considering

the great need to redirect public opinion on the subject, is there any

other choice?

be.

MISSION SUMMARY

22
In closing, there is this final footnote. A first grader went to

his school's library and asked the librarian for information about

caterpillars. The librarian responded by loading the youngster's arms with books on the subject until he could not see where he was going.

After a moment of troubled silence the remark was heard, "I didn't

want to know that much about catepillars ! " So it is in the field of

energy conservation. If the same question is asked today concerning

information on energy, there had best be a boxcar handy to carry the

load.

For those who are looking for a place to start, and for those

administrators wanting to recommend short readings to their staff and

enforcement personnel as the seeds for encouraging a broad and informed overview of the subj^^t, consider the following^ ^.Richard L. Crowther's book, Sun Earth and The Energy Primer by the

Portola Institute are two fairly basic source books for what is going

on in the field of energy conservation and for what is anticipated in

the years ahead. Obviously, there are thousands of other publications

available. These two, however, will provide a good first step in

understanding the magnitude of the task at hand and will offer some interesting and stimulating suggestions of where we might go from

here

.

23
FOOTNOTES

1. The American Institute of Architects, List of Building Codes and

Standards Publications , Codes and Regulations Center, Washington,

B.C. 1976.

2. Columbia Broadcasting System (CBS) New York Times, Energy Poll

for Television Energy Special . Shown August 31, 1977.

3. Architectural Record, Round Table on Cost Effective Strategies

for Saving Energy in Buildings , pp. 93-97, Vol. 162, No. 3. Mid-August, 1977.

4. "The Arkansas Story" Report No. 1, Energy Conservation Ideas to

Build On , Ownings/Corning Fiberglass Co.

5. Energy Research and Development Administration (ERDA) , Model

Code for Energy Conservation in New Building Construction: In- terim Code , Washington, D.C. 1977.

6. Building Officials in Code Administration (B.O.C.A.), Basic Code

Enforcement - Building Inspection , Chicago, 111., 1977.

7. Charriere, C. Lance, Improved Communications Between Code Officials and Building Design and Construction Groups Through

Education , National Bureau of Standards (NBS) Special Publication

473. 1977. pp. 303-389.

8. States with community college systems should consider using those

facilities to stage workshops to reach code enforcement personnel

in rural areas. Architects and engineers could be retained to

coordinate and instruct after they themselves have undergone

training sponsored by the state energy agency. In some instances, the community college may be able to offer code courses as part of its curriculum. There may be difficulty in

finding competent instructors, however, and reliance on design

professionals who are using the code may be necessary in instructing code enforcement personnel. While this may appear to be

the cart leading the horse, it none-the-less is a workable system

for getting architects, engineers and code enforcement personnel

together with syllabus guidance and overall planning and

coordination remaining with the state energy agency.

9 . Federal Energy Administration, Conservation Paper Number 43B , Energy Conservation in New Building Design - An Impact Assessment of ASHRAE Standard 90-75 .

Federal Energy Administration, An Energy and Economic Impact

Assessment of HUD's Minimum Property Standards , FEA/D-76/495

.

October, 1976.

10. Crother, Richard L. , Sun Earth , Crother/Solar Group, Denver,

Colorado. 1977

11. Energy Primer , Portola Institute, Menlo Park, California. 1974

24
RESEARCH ON NATURAL AND MAN-MADE HAZARDS:

IMPACTS ON BUILDING REGULATIONS

by

Daniel L. Schodek

Associate Professor of Architectural Technology

Graduate School of Design

Harvard University

Cambridge, Massachusetts

A crucial problem facing the building regulatory system in the

United States today is the question of how the results of current

technical engineering and scientific research into different natural

and man-made hazards that are dealt with by building regulations are

to be specifically reflected or incorporated into codes or standards.

Ad hoc responses of the building regulatory system to pressures from

different research groups, albeit well-meaning pressures, to

incorporate research findings with respect to specific hazards, may

lead to piecemeal implementation in which there is no underlying logic

which attempts to bring about a fundamentally consistent method of

dealing with all of the different hazards involved.

This paper speculates in an argumentative way on the role of the

building regulatory system with respect to new research and the

emergence of increasingly sophisticated scientific methods of

analysis. The paper addresses possible bases on which code structures

could be developed with the view of treating all hazard-related

measures consistently. Some conceptual difficulties are noted along

with more pragmatic concerns. In particular the point is addressed

that if regulations become more sophisticated in response to more increasingly sophisticated scientific or engineering methods of

analysis, then the possibilities for innovation and creative

approaches to reducing hazards are increased, but at the same time the

technical expertise of all those charged with enforcing the code must

also be increased. Therein lies a basic conflict.

A very fundamental issue raised is that the role of the law on which building regulations are based and what it can or should be in

relation to the scientific methods embodied in new research is

unclear. It is hypothesized that many of the dilemmas currently

facing the building regulatory system in regard to new research can be

resolved only by considerations involving a greatly extended

socio-political context.

Key Words: Building design; building regulatory system; decision

processes; hazards-related phenomena; innovations;

research findings; scientific methods; socio-political

system; technical expertise.

25
INTRODUCTION

One of the more interesting trends in construction that began in

the 17th and I8th centuries is the often slow but inexorable emergence

of the application of the scientific method to the design of buildings

to render them safe from natural and man-made hazards. A relevant

example is the field of structural engineering that developed in a relatively unhurried and orderly way. More recently, however, there

has been a literal explosion of scientific information potentially

applicable to the design of all, rather than selected, aspects of

buildings. There has been a very large amount of work done by the

scientific community, for example, in connection with the study of

fire as a physiochemical phenomenon. While the obvious hope is that

this basic research will yield new techniques for reducing fire

hazards in buildings, the exact role or position of the building

regulatory system vis-a-vis this research is still far from clear.

One reason for this is simply that the historical balance that has

existed between the building regulatory system and the methods of

science and engineering has been upset by the great influx of new scientific knowledge and a new balance has not yet been achieved. In

the past, a useful consequence of the originally slow gestation period

that was present for both the methods of science and engineering and

the simultaneously emerging law-based building regulatory system

(which was responding to similar goals in building design but in a more historically traditional way) is that an easy and often

supportive and interactive relationship existed between the two

fields. It is obvious that some of the early model codes of this

century, for example, were largely based on codifying the results of

then-current scientifically-oriented or technical inquiries made with

the intent of trying to find ways of reducing property and life loss.

As such one role of codes was that of a force for change and innovation in building practices. More generally, however, early building

bylaws also included traditional empirical measures deemed to be

necessary for the collective good.

More recently, the influx of new scientific methods that are potentially applicable to building design has created something on the

order of a crisis in the building regulatory field. There is no doubt

that the rate of development of new research knowledge will continue

to increase. The massive natural hazards program currently sponsored

by the National Science Foundation, for example, will undoubtedly

accelerate such new work. All remnants of traditional empirical measures found in building regulations will be challenged. Refusal of

the building regulatory system to immediately incorporate new research

findings into codes and standards will immediately cause some to brand

the system as counter- innovative and constraining — a sad s-tate of

affairs for a system whose roots lay in fostering innovative and

rational building practices rather than the converse.

While the potential long-run benefits of new research are self-evident, implementation of this new research into building

regulations must be done with care. Ad hoc responses of the building

26
regulatory system to pressures from different research groups, albeit

well-meaning pressures, to incorporate research findings with respect

to specific hazards may lead to piecemeal implementations in which

there is no underlying logic which attempts to bring about a fundamentally consistent method of dealing with all of the different

hazards involved. It has been reported, for example, that the value

implicitly placed on a human life by current codes is different for

provisions related to fire and those related to earthquakes as evaluated by a cost/benefit analysis (3) . The levels of protection

afforded are appreciably different. Whether or not the levels of

safety afforded should be exactly the same is worthy of debate. The

fact that they are unconsciously different is untenable -- at least

from the viewpoint of the scientific community.

This paper speculates on what form the results of current

research on hazards should take for implementation into building

regulations from two points of view. The first point of view is how to

develop an ideal form such that a uniform philosophy for dealing with

all hazards in a consistent way is possible so that a parity of

relative importance is maintained. What additional research is needed

to effect this type of approach is also considered.

The second point of view addresses the different question of how

to deal with the fact that if a more internally consistent code basis

were developed that could incorporate on-going technical research,

then a probable consequence is that the professional technical

expertise and sophistication of all the individuals dealing with the

code would necessarily have to be simultaneously increased for such an approach to be possible at a practical level. A related point

concerns the vast number of buildings built without the aid of

professionals at all, but which still must be controlled by the

regulatory system. These factors present unquestionable difficulties

with regard to implementing code approaches having the necessary

sophistication to be useful to implementing research-based

methodologies

.

Another fundamental point develops from inquiring into developing

a fully consistent method of dealing with all natural and man-made

hazards in buildings and some of the more pragmatic difficulties of

implementing such an approach. This is that the real dilemma involved

in the research and building regulations confrontation is actually one

of a far more fundamental nature dealing with the lack of clarity of

the law on which building regulations must be based with respect to

building design methodologies having their foundations in the

scientific disciplines.

It is suggested that the issue of how best to implement research

findings into building regulations is ultimately a political question

and it is in this arena that the issue would be most fruitfully

discussed.

The paper is speculative in nature and deliberately intended to

be argumentative with the intent of engendering useful debate on the

issues involved.

27
RESEARCH INTO NATURAL AND MAN-MADE BUILDING HAZARDS

Background

There are a large number of domains in which research is being

conducted that may potentially have implications for the building

regulatory system. Research in areas sponsored by the disaster and

natural hazards program of the National Science Foundation are obvious

examples. As a way of understanding the issues involved in the

implementation into building regulations of research of this type, it

is useful to focus the discussion in this paper on one of the most

important hazards, fire, and to a lesser degree on earthquakes. As

will be seen, there are common issues involved in the implementation

of any scientifically oriented research, and the precise hazard

discussed is only of secondary importance. Fire was selected because

it represents a hazard about which there has been a flurry of recent

research but which can be said to represent an emerging rather than a flourishing research discipline. It is particularly useful to look at

fire since the massive research funding provided by the National

Science Foundation has recently been largely terminated. Although

some fire studies are still underway, termination of the program has

obviously curtailed research efforts in this domain. A lot of work

has been completed, however, and it is of interest to speculate on the

consequence of this work vis-a-vis the building regulatory system.

Earthquake studies, by contrast, are currently receiving enormous

funding. A further contrast in that such studies are largely rooted in

the traditional methods of structural engineering, which is a fairly

sophisticated and developed profession as compared to that of fire

engineering. To be sure, however, many of the topics of concern in

earthquake studies are on the fringes of the traditional body of

knowledge extant in the profession and are delving into less

objectively based domains. As will be discussed, this last point is

of no small importance vis-a-vis the building regulatory system.

The following will briefly highlight some of the relevant

research work in the two hazard fields as a way of setting the context

for subsequent discussions on the role of the building regulatory

system in relation to this work.

Fire Hazards; Recent Research

While our knowledge of the phenomenon of fire in buildings is not

as empirically based as it once was, there is little doubt that

practitioners dealing with fire control in buildings are forced to

rely on analytical tools that are considerably less sophisticated than

comparable tools used in other professions. Numerous examples could

be cited to illustrate this point. Perhaps the most salient is the

current inability of fire engineers to analytically predict the course

or effect of a fire and its related phenomena, e.g., spread of toxic

gases or smoke, in any particular building space that has been

completely defined in terms of its geometry and materials and where

there is an assumed point of ignition. The progress of a fire cannot

28
be adequately predicted for these circumstances involving only a building shell. The more realistic case of a situation involving

"random" elements such as odd pieces of furniture or scattered

clothing is even further beyond current analytical capabilities.

To the average fire engineer plying his traditional craft, the

absence of such analytical capabilities is probably not startling, nor perhaps are such capabilities even viewed as nececessary to make

building safe. To members of other disciplines in the scientific

community, however, the lack of such capabilities is often regarded as appalling. The perceived issue is usually not so much one of whether

or not the particular activity described is of value or not as a necessary building design tool, but that the state-of-the-art in an

area apparently susceptible to scientific methodologies is so retarded

as to not have applied such methodologies. It is invariably

implicitly assumed that science-based methodologies would prove useful

as building design tools. Such is the confidence of the scientific

discipline

.

that the state-of-the-art is as it is, however, should not be

surprising for some very good reasons. One is that fire is a very

complex physical and chemical phenomenon not readily susceptible to

rational analysis. Until the recent financial backing provided by

various private and public agencies, there was simply insufficient

incentive for members of the scientific community to study fire in

buildings and to provide the necessary theoretical understanding of

the phenomenon necessary for more sophisticated engineering approaches

to be developed.

Now that there has been a spate of sponsored research in the

area, however, it is of interest to assess briefly the new state-of-the-art. In general, types of recent research can be

classified into two very broad categories: basic and applied. The

first concerns basic scientific research into fire as a physical and

chemical phenomenon. The long-range goal of this research is

generally to establish a better understanding of the factors that

control the ignition and growth of fires. The emphasis of this type

of research is on gaining a theoretical understanding of fire as a process without regard to whether the fire occurs in buildings or in some other context. Thus, the findings will contribute to an understanding of fire in buildings but are not necessarily directly

applicable in an obvious way to their practical design. The second

category of research is based upon our current understanding of the

theoretical aspects of fire and is consciously oriented toward

achieving results that can be applied directly to the design of

buildings for fire safety. Efforts in this second category generally

fall into one of two types: studies that are directed toward

improving the general level of fire technology and that are thus

broadly applicable, and studies that are geared toward reaching the

fire hazard in specific situations.

With respect to basic research, a review of most research studies

either recently completed or underway reveals that most of the

research is still currently in a stage of infancy, particularly those

29
dealing with understanding fire as a physical and chemical phenomenon.

Enormous strides have been made by the scientific community in this

respect, but most studies were built on a dearth of prior research and

largely represent fundamental efforts.

The subjects addressed by basic research studies are fairly

wide-ranging. Studies have been made, for example, of heat transfer

by convection and radiation. These phenomena are of basic importance

since the rate of fire spread in an enclosure such as a room is a function of the heating, by the fire itself, of nearby but still

uninvolved fuel elements. Failure to recognize radiative and

convective influences would make it impossible to predict accurately

the path of a fire in a given situation. Other studies on the

pyrolysis process are important in describing the ease of ignition of

materials. Studies of the basic mechanisms by which water or other

agents put out fires are of obvious value. Exactly why a wind blowing

over a match may extinguish a flame, for example, may seem to be a simple question to answer, but to the scientist seeking to precisely

describe the principles involved, the answer is surprisingly difficult

to provide.

Studies on the behavior of combustion products are resulting in

computer simulations of the way these gases are distributed over time

in an enclosure. Other types of computer models are being developed as well

.

A traditional method of science has always been experimentation.

Experimental studies seeking to develop or provide generalizable

theoretical constructs include exploring ways of accurately modeling

on a small scale a complete fire history for any governing set of

variables. Pressure and atmospheric modeling techniques, for example,

are being developed. Related studies include correlating experimental

data for model tests with those of full-scale tests of simulated

bedrooms. Modeling techniques of this type are potentially enormously

valuable. Modeling techniques, for example, are commonly used in many

other highly sophisticated engineering disciplines, e.g., the

aerospace industry, to great advantage. There is every reason to

believe that they would be of similar value with respect to fire

engineering.

Supplementing work on fire as a phenomenon are basic studies

considering the bio-medical consequences of fire on building

occupants. Human sensitivity to fire and fire-related phenomena are surprisingly uncharted.

Studies of the type outlined above are paving the way for a complete theoretical understanding of how a fire ignites and

progresses in a building and its effects on occupants, but it is

evident that this understanding is far from fully developed. There is

still a long way to go before dealing with fire hazards in buildings

really achieves the level of an engineering discipline of a stature

and assurance comparable to that of disciplines dealing with other

hazards, e.g., the structural engineering profession. A continued

gestation period is needed. The important point is, however, that the

30
theoretical bases for engineering are currently being laid and that,

if given encouragement and the opportunity to apply findings, fire

engineering could indeed develop into a sophisticated profession.

Fire Control Approaches Suggested By Research

Before looking at what stance the building regulatory mechanism

should take in relation to the type of work briefly described above,

it is useful to simply speculate on the potential type of future code

provisions that the research seems to inherently suggest. With

respect to fire, much of the research mentioned--including numerical

analyses and modeling studies in both full and reduced scale-point to

the general possibility of computing the progress and consequences of

a fire started at any assumed spot in a room whose geometry and

contents have been specified. Perhaps eventually this could be done

for a complete dwelling unit. This is, of course, more than a slightly optimistic view when one looks in more detail at the

analytical difficulties involved in relation to the research results

achieved thus far. Still the potential analytical capability

mentioned is not an unreasonable aspiration.

It might, however, be questioned as to whether meeting this

aspiration is really necessary to ensure the fire-safe design of

buildings. Could not, for example, many of the current design

problems be corrected by paying more attention to devising more thoughtful tests for material behaviors under fire conditions?

Frequently used measures such as "Flame Spread Ratings" have, of

course, been under wide attack as of dubious value by some researchers. While testing improvements would undoubtedly yield some benefits, it is evident that no matter how much attention is paid to

material characteristics, a basic difficulty still underlies the

successful application and use of ratings of individual materials as a way of reducing overall building hazards. The flaw is an obvious one known to most fire engineers and is most simply explained by what is now a classic example. It is amazingly difficult to start and sustain

a fire with one log regardless of its material susceptibility to fire

as measured by a criterion such as a Flame Spread Rating. However,

with the addition of a second or third log placed in close proximity

to the first, a fire once ignited can be sustained and made to grow

rapidly. This phenomenon can be described primarily in terms of

radiative feedback. A single-valued descriptor of the flammability

for any given material does not adequately describe its actual

flammability when it is placed adjacent to itself or other

substances. It may well be possible to assign a meaningful

flammability index or rating to a system of several logs, but this

index would have to depend as much on the characteristics of the

system, including its geometry, as on the characteristics of each

specific element within the system. This dependency of the fire

sensitivity characteristics of the assembly on the nature of the

relations between elements as well as the geometry and material

characteristics of the elements themselves, is the fundamental reason

that tends to justify and give credence to the aspiration initially

described of attempting to devise a full, analytical capability for

predicting the behavior of a fire in a given context.

31
Assuming that such analytical capabilities did exist, the type of

code provisions immediately suggested are those that make use of

allowable rating systems to establish acceptable levels of fire hazard

for whole functional units such as particular rooms or entire

dwellings. Rating scales of this type would have to depend on the

geometric characteristics of the spaces and the specific characteristics of the materials used and would, therefore, be based on the

susceptibility of the system as a whole to fire. This method is

potentially far superior to the assignment of single-value descriptors

to individual materials without accounting for the geometry of

material placement and is a realistic way of potentially controlling

fire hazards in buildings.

The precise nature of an allowable rating system applying to

whole functional units can only be guessed at. Ideally, it would

still be a single-valued descriptor, but of necessity the descriptor

would probably have to be composed of a weighted combination of

several more specific indicators such as ease of ignition, rate of

spread of flame, smoke, and toxic gases. Closer study might indicate,

however, that any single-valued descriptor based on several specific

indicators would be meaningless and would have to be replaced by a series of individual allowable ratings for controlling specific

phenomena in a functional unit. Associated with the rating method used

might be time criteria governing the periods for maintaining the

integrity and safety of different kinds of occupancies during fires.

An advantage of the use of overall ratings for functional units

is that the exact ratings could be made to depend upon the occupancy

involved and the degree to which human safety is a concern. In

buildings where human safety is not an overly critical issue, for

instance in warehouses, the ratings could be tuned to be responsive

primarily to property protection. In cases where life protection is

of paramount imp^ortance, for example, in housing, a rating system

primarily responsive to life safety could be used with implicit

measures, such as rate of smoke or toxic gas-spread especially

emphasized. The latter could even respond to different occupancy

groups within housing. Distinctions could be made for dwelling units

housing the elderly and those housing large family groups. As

mentioned, different variables among these ratings might reflect the

importance assigned to controlling specific phenomena, such as time to

flashover, ease of ignition, and the rates of spread of flame, smoke

and toxic gases.

Attention could be given to the possibility of linking

requirements with the degree to which building contents could be

controlled. Rightly or wrongly, many buildings constructed in

accordance with current codes have been characterized as well-fabricated incinerators able to withstand a burnout of highly

flammable contents. While there are obvious difficulties in

controlling building contents, the linking of requirements with

contents may be possible in certain types of residences such as dormitories where many of the furnishings are built-in.

32
It is evident that if a system of the type outlined could indeed

by implemented, the opportunities for creative innovation in design

would be enormously improved. Traditional measures such as height and

area limits which dramatically affect building design (see ref. 5),

for example, would no longer be needed since the goals they were

intended to accomplish would be implicit in the more sophisticated

system. If such measures were tied into occupancy types, then the

regulatory mechanism could truly be said to be "responsive."

The above discussion is at once as serious and well intentioned

as the author can muster but is also ever so slightly on the tongue

and cheek side as well, with the intent of the latter to bring into

focus two of the salient problems facing the building regulatory

mechanism--that of setting reasonable criteria and that of

establishing the limits to the extent of the context considered. On

what basis would be exact numerical values of ratings for functional

units be established and what is the degree of scientific reliability

of the criteria employed? Should the criteria be based on considerations related to an extended context or a more limited one,

i.e., should criteria be related to "housing" or "housing for

low-income families." A more extended system of the type described

would, of course, be the joy of academics throughout the land because

it has the guise of scientific credibility, but at the same time

begins pushing into less objective grounds. Implementation of the

idea of linking criteria with occupancy types and doing things such as varying the relative weights of measures--from ease of ignition or

rate of toxic gas spread to whether the building is occupied by

elderly or low-income families--would require massive amounts of

research into domains that simply cannot be said to have the almost

brutal credibility of those associated with the so-called "hard

sciences." It is interesting to note, however, that as the frontier

is pushed in the softer direction, more opportunities appear to open

up for truly creative and responsive design.

It could even be argued, for example, that emphasizing hard

science criteria at the expense of less objective measures may well be

detrimental to fulfilling the mission of the building regulatory

mechanism in assuring the safety of building occupants by virtue of

misdirected priorities and resource allocations. It is undoubtedly

true that insufficient attention has been placed on subjective

considerations in life safety during fires. It is evident, for

example, that people under duress in fire conditions resort to the

familiar routes of escape or those that seem innately reasonable, no matter what "exit" signs may say. There is good reason to believe

that buildings could be so architecturally designed as to communicate

innately appropriate rather than inappropriate senses of proper

evacuation routes and thereby be more effective in protecting the

safety of occupants than all of the prespecified code mechanisms put

together. This is, of course, an extreme position and one which

would, no doubt, have to be tempered when faced with the realities of

building design.

Reflections of the above type, of course, are nothing but

anathemas to officials in the building regulatory mechanism charged

33
with assuring the safety of building occupants while at the same time

being responsible for creating documents that have the force of law

and which should seem, therefore, to have as much objectivity as possible. It may well be desirable to set a limit on the type of

research findings that should be included in code documents having the

force of law with other types transformed into standards or guidelines.

Earthquake Hazards

In contrast to the research on fire briefly described above which

has been built on a dearth of prior research, recent work on earthquake hazards has been able to begin at a much more developed

level. The basic analytical capability, for example, of taking a given structural configuration of physical elements of specified

material properties and being able to a priori predict the behavior of

the system reasonably well with respect to an applied set of loads has

existed for a long time. This existing capability is surprisingly

analogous to that now only aspired to by fire engineers of computing

the progress of a fire through a given configuration of physical

elements. To be sure, however, the dynamic phenomenna is buildings

that are associated with earthquake movements are highly complex, and

there exist a whole host of questions that remain to be answered

before our theoretical understanding of earthquake hazards can be said

to be complete. Quantitative input data describing possible ground

movements, for example, are surprisingly sparse, and our knowledge of

site and structure interactions or of the exact role and behavior of

non-structural building elements is similarly on the vague side--at

least when viewed in terms of quantitative predictability.

If significant, unsolved problems didn't yet exist, then the

massive recent funding for earthquake research would indeed be curious

(albeit a significant portion of this funding is not directed towards

technical studies). Still, by and large, the knowledge level and

technical expertise in the area that is already currently available is on a far more sophisticated plane than is our technical expertise in

other domains related to building performance.

An interesting aspect of the fact that current earthquake hazard

research is starting off on a relatively high plane of development is

that many studies are pushing the frontiers of technical research into

domains that are considerably more value-laden and subjective than

ever before. Obvious examples are those studies that are taking

cost/benefit approaches or those dealing with risk-balancing

techniques. It is into domains such as these that the logic of much

research leads as it seeks to find rational bases on which to make

decisions or evaluate alternatives. Despite the fact that many of

these studies are done by credible scientists or engineers, the measures used are often far less susceptible to traditional methods of

scientific vertification than are those encountered in classical

structural research firmly based on well established principles of

mechanics

.

34
BASIS FOR TREATING HAZARD PHENOMENA CONSISTENTLY

Background

While incorporating some of the suggested provisions made in

relation to fire may make sense with respect to controlling that

hazard, they may not make equivalent sense with respect to a general

code philosophy directed towards taking a consistent attitude to

general hazard control in buildings. It is reasonable to think that

there should be some consistent method of dealing with suggestions

stemming from different hazard (e.g., fire, earthquake) study areas,

since they are addressing the same general goal of reducing risks to

building occupants due to natural or man-made hazards.

The problem, however, is one of answering the question of the

basis on which provisions dealing with different hazards can be

logically compared. The natural phenomena associated with fire, for

example, are very different from those associated with earthquakes.

It follows, therefore, that the only way a consistent basis can be

established is not to deal directly with measures related primarily to

the phenomena themselves, but to deal with measures related to the

effects of the phenomena on the occupants of a building, the

activities therein, or the physical property itself. Many

investigators have, of course, realized this principle, and have

either developed tools to address the issue or have borrowed them from

other disciplines. It is of interest to review in general terms the

basic approaches developed thus far or that have been proposed. It is

suggested that provisions such as those previously described related

to fire can be used, but that the bases underlying any numerical

criteria used must be found on more general grounds.

Current Approaches

For purposes of this brief discussion it is useful to

simplisticly divide the relevant approaches suggested thus far into

three general categories: (1) cost/benefit analysis, (2) death or injury-risk analyses, and (3) multiattribute decision theory.

Cost/benefit analysis is, of course, a commonly-used tool for

reducing certain types of problems to common bases. In such studies

all losses are expressed monetarily. The losses can be either direct

property losses or less tangible fatality, injury or societal costs.

Application of this general approach to assessing the economic impact

of building codes has been convincingly demonstrated in a mostwelcome, recent paper by McConnaughey (4), While cost/ benefit models

are most useful for studying economic impacts, they have also been

used for selecting alternative ways of allocating resources with the

intent of minimizing human suffering.

Whether or not analyses that are basically economic in nature

should be applied as a basis for developing criteria for building code

provisions intended to assure the force of law is an interesting point

of conjecture. Proponents of the method of course point out that not

35
taking an economic orientation is unrealistic; others argue that this

point should be debated more.

On a more pragmatic plane, it is important to note that from the

viewpoint of hazard evaluations, applications of cost/benefit

approaches necessarily require placing a value on human life. While

such a notion may seem shocking to the uninitiated, the act of placing

monetary values on human life is commonly done in many connections

affecting our daily lives (e.g., insurance matters). Of interest

herein, however, is not the morality of the question, but rather that

such measures must be value-laden and dependent upon a host of

variables to the extent that they cannot be said to have the

credibility of hard-science measures. Used correctly as aids in the

decision-making process, however, such models can still be of enormous value

Interesting approaches which deal exclusively with the risk of

death of injury and not at all with monetary values or economic

impacts have also been developed. Starr (6) has evaluated risk of

deaths from various causes. Risks are classified into those

associated with voluntary activities or involuntary activities. In

the first case an individual is knowingly exposing himself to a risk

and naturally adjusts his exposure to the risk accordingly.

Involuntary risks are those to which an individual is exposed by an external source. Clearly the type of risks associated with hazards in

buildings are of the latter type. Interestingly enough, Starr

estimated that an individual is on the order of 1000 times more willing to accept voluntary as opposed to involuntary risks. Wigging

and Moran have suggested, for example, that risks on the order of 10

fatalities/person exposed/year might be used as a basis for earthquake

design requirements (9). Like cost/ benefit analyses, however, such measures are extremely value-laden and involve subjective assessments.

Various combination approaches can be taken which deal

simultaneously with risk of death and monetary evaluations. These

multiattribute approaches deal with problems in terms of

characteristics considered most relevant. However, the two models

previously discussed represent clearer approaches and are more useful

as discussion vehicles for clarifying issues, although a multiattribute approach might well prove most attractive in the long run.

Either a cost/benefit or risk of death analysis could be used as the basis for establishing building code provisions related to natural

and man-made hazards in buildings. It is perfectly possible, for

example, to imagine a code system stemming from a cost/benefit type of

approach whose provisions were based on criteria related to the value

of a human life. Criteria would be established such that the

stringency of all provisions governing hazard-related phenomena, no matter what hazard was considered, places the same value on a human

life. The important point is that such a criterion could provide the

necessary common ground for establishing criteria for diverse hazards

such as earthquakes and fires.

36
Alternatively, a risk of death approach could be used (based on

the involuntary exposure category) that basically accomplished the same goal, except that the criteria used would be expressed in risk

terms rather than monetary values. Provisions could be adjusted such

that the same death risk was present with respect to all hazards.

Since the mission of a building code is to ensure the safety of

building occupants, the notion of going to death risk criteria and not

to criteria involving economic implications certainly has great con- ceptual appeal.

It should be noted that while the basic criteria might be of the

type described above, specific provisions could still be more explicitly related to the hazard phenomenon of concern. It is just

that their stringency would be determined on the more basic criteria

discussed.

What level these basic criteria should assume (e.g., what is an appropriate numerical risk level or value of life) is a topic of

inquiry beyond the scope of this paper--other than to note that there

is no reason why a parity should not be established with other

criteria explicitly stated or implicitly present in other systems

affecting the public. That there should be differences in risk levels

present in public buildings and public transportation systems, for

example, is not really explicable. On the other hand, while a grand

risk-balancing approach certainly has conceptual appeal, it is

interesting to note that it is unclear exactly why risk from different

hazards should be balanced and code provisions designed accordingly,

other than that it does not seem sensible not to balance them. This

interesting point should be pursued in depth if a risk approach is to

be adopted. Not all researchers believe that these more commonly

discussed methods described above (benefit/cost or risk of death

analysis), are the most appropriate techniques to use in setting

public policy. De Neufville, for example, notes that such analyses

may lead to incorrect and unacceptable recommendations (1). His

argument is based on data demonstrating that the public's evaluation

of any protection against hazard damages is both a highly non-linear

function of its level and the level of other benefits and varies among

different elements of society. He proposes an alternative criterion

when approximate evaluations are appropriate and when a more complete

assessment of the values used by a different interest group is

required. It thus appears that there yet exists conceptual

difficulties in formulating a consistent basis for evaluating the

effects of different hazards. Coupled with the conceptual

difficulties noted are more pragmatic concerns. McConnaughey has

noted the incredible effort it takes simply to evaluate, using a cost/benefit approach, a few limited provisions (4).

Full scale implementation of any of the approaches described is

really a rather grandiose aspiration at the moment. The question

addressed, however, is not one of how to immediately implement such

approaches, but whether or not aspirations of the type described are reasonable as a consistent code basis. Whether or not codes of the

next century should have such bases is really the issue at hand. If

so, then we can begin slowly working in this direction. If not, then

37
we had best establish another direction or the floundering will only

get worse. A critical issue for debate from the building regulatory

viewpoint seems to be the objective credibility of the measures and

criteria suggested thus far. A fundamental difficulty seems to be

that the frontiers of technical research are encountering far less sure ground than that covered before. While the efforts to cope with

this situation are admirable, the difficulty nonetheless remains.

IMPLICATIONS FOR THE BUILDING REGULATORY MECHANISM

Background

It is obvious that the building regulatory mechanism has quite a task in front of itself with respect to how to (indeed, if it should

at all) rationally incorporate recommendations or procedures stemming

from the type of research briefly described. It is almost invariably

true that any researcher would like to see manifestations of his or her work appearing in documents such as building codes. The reasons

for this are self-evident with the good intentions and convictions of

the research as to the need and potential value of such incorporations

playing a major role. The pressures brought to bear on the building

regulatory mechanism to respond in some way are often enormous. After

all, it is often supposed, are not devices such as codes merely

artificial constraints placed in the way of innovation? While this

latter point has been dealt with quite well by others, e.g.. Ventre

(8), the pressure for change nevertheless remains--as well it should.

No building code can remain static and hope to continuously fulfill

its original mission as a force for positive change of building

practices for the benefit of society.

There is good reason to believe, however, that there should be some element of conservatism in how the building regulatory system

responds in that changes made assume the force of law. Assigning to

the building regulatory system the role of a vast, experimental

laboratory is an interesting, but more than slightly unsettling idea.

There are far too many examples in the history of science and

technology where many has used the power of these tools to effect

certain results only to find that other unanticipated, and perhaps

undesirable, consequences have also resulted.

From the building regulatory viewpoint, the issue of change is

not whether responsive change is undesirable, for few in the system

other than special interest groups would argue this, but rather what assurances exist or can be developed that any changes made will indeed

contribute to the collective good of the very society that legislated

their existence. A far more pragmatic consideration is that the

building regulatory mechanism is huge and complex. Instead of buzzing

about, it moves necessarily in slow and ponderous steps. The

consequence is that once major changes are made, they are incredibly

difficult to rechange. A related point is that once minor changes

with respect to certain phenomena are made, it is often very difficult

to effect more major changes with respect to the same phenomena within

38
any sort of reasonably short time period. For example, it is evident

that this very point is one of the principal issue underlying the late

controversy of whether or not the so-called "corner test" should be

used as a basis for establishing flammability ratings for materials

and replace existing tests. Some researchers maintained that the corner test was far better than existing methods. Others who were concerned felt that while the test was perhaps slightly better, it was

still of intrinsically dubious theoretical value, and that direct

adoption as a standard test would only impede the eventual adoption of more meaningful approaches. Pragmatic though it may be, the point is

a serious one.

Parity Level Considerations

A fundamental concern underlying the example cited above is that

of the danger of piecemeal approaches to implementation of research

findings in which changes not made in accordance with a carefully

thought-out set of guidelines reflecting a logically consistent code

philosophy are apt to prove more counterproductive in the long run,

despite their immediate innovative quality.

On a more general level, it is evident that the same danger of

piecemeal approaches exists with respect to the simultaneous

incorporation of research results dealing with the many different

hazards currently being studied. As the brief state-of-the-art review

presented earlier indicates, the levels of development of engineering

expertise with respect to fire and earthquake hazards are remarkably

different. It will be some time before a parity of development is

reached. This difference in levels poses a very great problem for the

building regulatory mechanism, since it is evident that on the one hand there is the pressure for change in areas that can be changed,

while on the other the dangers of a piecemeal approach exist. It is

not suggested, however, that the building regulatory mechanism sit

idle because of a perceived danger. It may well be that wholesale

changes could be made with respect to how some hazards are treated

with the intent of setting up a model for how to treat other hazards

when their levels of technical sophistication achieves a parity. That

this is a valid approach, however, remains to be demonstrated in a thoroughly convincing way. The whole question of whether interim

modifications become models for change or, less desirably, obstacles

to future development is one which needs more thought than has been

given to it and is suggested as a prime research topic.

In any event, it is evident that eventually a parity of technical

expertise with respect to different hazards can be achieved and that

it is desirable to begin setting up a code structure that will allow

for a consistent treatment of different hazards. It is suggested that

an immediately useful and beneficial role that the government or private funding agencies could play vis-a-vis supporting innovation in

the building regulatory field is that of sponsoring research such that

parities of comparable technical expertise are developed with respect

to different hazards.

39
Confidence Level Concerns

A fundamental point of concern for the building regulatory

mechanism undoubtedly lies with some of the problems addressed

earlier. In particular the problems of establishing on what basis

criteria are set for consistent methods for treating different hazard

phenomena and for setting limits to the extent of the context

considered in formulating criteria. The basic problem is that, as approaches become more sophisticated and the context of concern is

extended, there is strong reason to believe that the possibilities for

innovative design are increased, while at the same time there is a tendency for the measures that are involved to become more subjectively and less objectively based with a decrease in confidence

in the measures resulting as a consequence. Suggestions have already

been made with respect to how these problems might be treated. It is

evident, however, that the conceptual difficulties present are of no small magnitude, and the most appropriate stance that the building

regulatory mechanism could or should take is decidely unclear. It is

evident that the building regulatory mechanism could potentially act more decisively and with greater confidence if some of the conceptual

difficulties in the criteria suggested by scientific researchers were more uniformly convincing. Alternatively it should suggest its own. Whether the building regulatory mechanism would act, however, is

another story. To use concerns of the type noted above for total

inaction would perhaps be seeking an excuse for inaction rather than

believing in the issues involved.

The Nonappropriateness Problem

Implicit in the discussion thus far has been the tacit assumption

that once research results are available to pave the way for more theoretical understandings of different hazard phenomena, such

understandings can be immediately applied to the building field in a practical way. This assumption, is, of course, questionable on a number of grounds. One of these is simply the issue of exactly who

would make sophisticated analyses of the type described, e.g., rating

the fire hazard for a whole functional unit in numerical terms. It is

not unreasonable to believe that for large special projects, teams of

individuals having the necessary specialized knowledge could indeed be

assembled. The real difficulty lies not with major uniquely designed

projects, but with more run-of-the-mill minor building projects. Most

privately developed single-family detached housing and multi-family

low-rise housing in this country, for example, is normally built

without the aid of professional architects and engineers.

For buildings such as single-family detached housing, codes using

provisions of the more sophisticated type described which would

involve features such as allowable ratings for rooms would probably

work very poorly. The question of who would analyze the dwelling unit

of concern and establish the actual ratings to compare with those

promulgated in regulations looms very large. It is more than doubtful

that the average contractor could perform such an activity, or, for

that matter, the average building inspector or city code official

charged with enforcing the promulgated regulations. The latter can

40
check on an individual basis whether a particular material is

acceptable, for example, but if the question of acceptability were linked to the actual use and relative placement or positioning of the

material in a given situation, it is evident that personnel relatively

untrained in engineering would not be equipped to handle such

questions. Professional engineers having extensive theoretical

training in fire hazards could, of course, be required to approve or assess plans. It is clear, however, that requiring such involvement

would add more to the difficulties already present in getting a new

house underway. There would also be new costs for additional

services, probably comparable to the one or two percent of total costs

associate with the fees of comparable professional structural and

mechanical engineers. A further complication might be additional time

delays

.

The basic difficulty that underlies this discussion is that, as a regulation becomes more sophisticated, the possibilities for

innovation and creative approaches to fire safety are increased. As

the level of sophistication increases, however, so must the expertise

of the people who actually implement the regulations.

Whether professionals should be involved in all building designs

is an often fought question and the crux of the matter. Of interest

herein is that building regulations are ultimately promulgated by

society itself for the purposes of protecting the collective good of

society. If it can be demonstrated that the larger collective good of

society is best served by not accepting the important but restricted

values that a science or engineering based approach offers, then

society, of course, can choose the option not to require professional

involvement. It is possible, for example, that the increased costs

associated with professional involvement would be sufficient to make

the aspiration of assuring decent housing for all low-income families

even bleaker than it currently is. With respect to some building

types, it is, therefore, possible that professional involvement might

not best contribute to the larger collective good of society.

Obviously, there are trade-offs involved, notably the possibility of

decreased risks to occupants through the involvement of professionals,

that need to be assessed before this critical question can be

resolved.

If a nonrequired involvement of professionals for the design of some building types is deemed to best serve the collective good of

society, then the dilemma facing the building regulatory mechanism is

obviously enormous. It needs to at once address two fundamentally

different types of groups involved in building which radically differ

in not only their values vis-a-vis building, but in their specific

design approaches as well.

The conflict discussed above is true with respect to other

hazards than fire. It is entirely too fundamental for there to be any

easy solution for the building regulatory mechanism to pursue. A

possible option that has been repeatedly advanced and repeatedly not

caught on as a viable approach, with good reason, is that of a code

structure in which a dual format is used. The obvious intent is

41
usually to provide simultaneously the type of provisions that are most

appropriate to the user. In the frequent arguments about the relative

merits of performance versus specification provisions, for example, it

is usually suggested that performance measures be allowed as an alternative to specification type provisions. Many building officials

and others have argued, however, that such a format is not only

confusing, but also redundant, since model codes are already largely

performance oriented. Still, given the dilemma involved, it may make

some sense to revive discussion about the dual format notion but with

a different twist. Instead of the intent of a dual format notion

being to escape the application of specification provisions, the idea

would be to do so with the intent of encouraging them for those that

wish to use them. It is suggested that a more strongly specification

type approach for certain building types, albeit a streamlined one,

than is currently present in model codes might well prove a desirable

option not only to a great many builders who pursue their trades

without the alliance of professional architects and engineers but to

society at large whose best interests are often best served by

expediting building. By a similar token, the provisions that are intended to expedite application of the scientific method by trained

professionals should be made as abstract as necessary to best serve

the perceived needs of such groups. The problem of cumbersomeness and

workability still exists, but the different twist suggested may prove

beneficial in the long run.

BASIC RELATIONSHIPS

Looked at in a fairly abstract way, it is evident that many of

the problems and conflicts described above stem from the fact that the

building regulatory mechanism is a manifestation of a socio-political

system, while the roots of scientific methods ostensibly lie

elsewhere. The word "obstensibly" is deliberately used since the

point about the roots of science lying elsewhere is utlimately a point

of interesting conjecture. Of interest at the moment, however, is

that if science ever deliberately chose to regulate itself, or found

such a necessity imposed upon it, it is certainly doubtful if it would

choose a vehicle having the characteristics of the building regulatory

mechanism. Now that some of the more conceptual aspirations and

pragmatic difficulties of applying scientific methods to building

design have been addressed, it is useful to speculate more abstractly

about the relation of scientifically oriented building design methods

to the foundations of the building regulatory system-- the law.

An extremely interesting argument very relevant to the issue

discussed in this paper has been advanced by Ferguson (2) who has

maintained that the methods of law are not adapted to technological

information in the sense that the two systems are basically different.

Law, he argues, is arbitrary and precise and regulates real

situations, things and entities, whereas technology deals with

universal abstracts and relations.

While the thesis mentioned above could be argued, and will be, it

is of interest to temporarily expand the thesis slightly to clarify

42
some of the issues involved. A common feature of all building design

activities based on the scientific or rigorous engineering

methodologies is that they invariably deal with the act of positioning

physical elements and formulating associated interrelationships with

the objective of imparting a desired performance attribute to the

total system. The consequent result is that a different answer is

provided for each situation depending on the context involved. The

structural engineer performs such activities, albeit less abstractly

conceived, as a matter of course, as do more sophisticated fire

engineers. Therefore, since the law is based on a body of precedents

established by real situations it is peculiarly unsuited to dealing

with methodologies which produce design solutions not based on any

analogous precedents at all, but on an understanding of physical

phenomena. By a similar token, the law is uniquely suited to

specification-type provisions which are, of course, firmly based on

real precedents.

If the conclusion is drawn, however, that the law is not

potentially capable of coping with changing approaches and new

methods, an error is made in underestimating the flexibility of the

legal system. A good example of how the legal system has already

responded to innovative changes in methodologies is the rise of tort

law in the 19th century, which was conspicuously linked with the rise

of industrialism. The notion of tort law is of interest here for a number of reasons. With respect to building, a builder has

obligations placed on him by society over and above those explicit in

the realm of contractual liability. Society, through the legal

system, places the obligation not to injure others on all of its

members. This obligation is of a civil nature. A breach of this

obligation may give rise to an action in damages by the injured party.

That action lies in tort. While it is difficult to express briefly

the role of tort law, one of its primary functions is to distribute

the losses that arise through human activities. While having some punitive aspects, its principal function is to establish whether an individual who suffers a loss can shift that loss to the individual

whose conduct or activities have substantially caused that loss to occur. Tort law has, for example, long been the legal basis for

losses incident to construction procedures.

Also of interest are those principles of law that deal more directly with faulty design. In the manufacturer's liability field,

many situations involving injuries due to faulty product design have

been moved by the court to tort (7). In those cases where faulty

theoretical design (not workmanship) has involved deaths, the

situation is even more vague. This is not to say that opinions do not

exist or that actions have not been taken, only that the principles

are not as settled as in other areas.

The more the relation of the law and activities stemming from

application of the scientific method is looked into, the more it is

evident that a far from clear and precisely definable relationship

exists. Since buidling codes have their basis in the law, there are undoubtedly implications of this unclear relationshp--most of which

have yet to be explored. One consequence, however, is obvious. It is

43
evident that the problems involved can never be easily resolved

without addressing the problem of the relation of the law to the

scientific method in more fundamental terms and coming to grips with

the issue at this level. The idea that a group of building code

officials and scientific researchers, neither of whom are usually

particularly well versed in legal issues, would be capable of

resolving any conflicting perceived missions without involving a larger context of concern is unrealistic. The confrontations would

simply take place in a context beyond their control and which

preordains a certain measure of irreconcilability. It is evident that

strategies for attaining implementation of research must be developed

in relation to a much larger context and, consequently, involve

participants other than just code officials and scientific

researchers. Obviously this is a suggestion for what might well be a potentially fruitful area of general research which is currently

relatively unexplored.

Looked at in what is perhaps a naively simple way, for example,

the result of a more extended inquiry taking place in a larger context

might well indicate that the only type of relationship that could

exist in which the scientific method could be exercised in a totally

unfettered way, thereby potentially opening up opportunities for

innovation, is one which does not include any sort of building

regulatory system of the type we currently have at all. Rather the

mechanism by which society might choose to protect itself from hazards

might be one in which the law enters in only if losses (including

death and injuries) are incurred that were thought to be actionable,

in which case the issue involved would be decided in court. This

prospect is either intriguing or frightening, or perhaps both,

depending on the perspective assumed. The implications of such an approach, however, are literally too enormous to be explored in a brief paper. It might well be, however, an option to consider as a viable approach to be taken to prevention in the future--the distant

future to be sure. Planning strategies for the next century, however,

is useful both in its own terms and as a way of clarifying issues for more immediate action.

SUMMARY AND CONCLUSIONS

For those seeking immediate solutions to pressing problems, this

has undoubtedly not been a very optimistic paper. A primary

hypothesis underlying this paper is that the possibilities for true

innovation in many aspects of building design are possible only if the

scientific method can be employed in an unfettered way. Over and over

again, however, the point was raised that many fundamental problems

exist in the incorporation of new research into code documents. The

extent of these problems is such as to suggest that the real unsolved

research problems of relevance to the building community lie not so much with uncertainties in the theoretical body of knowledge that is

existent, but simply in what to do with the findings already available

or which will soon become available.

44
To summarize a few salient points raised in the paper as a prelude to some final suggestions, it was noted that the one thing common to methodologies of potential usefulness in building design

that have been suggested by research in different hazards is that all

deal with the positioning and relationships of building elements to one another in addition to dealing with the physical characteritics of

the elements themselves. This was found true with respect to both

earthquake and fire hazards. This same notion also characterizes

other applications of the scientific method to building design as well. Unless some sort of generalized way of coping with operations

involving the positioning and relating of building elements in

building regulations on a consistent basis can be developed, it is

doubtful if there will ever be anything but an uneasy situation

existing between the building regulatory mechanism and research

groups. The best strategy for accomplishing this end currently seems

to be the adoption of measures that are based on the effects of a phenomenon such as an earthquake hazard on the occupants of a building, the activities therein and/or the physical property itself,

rather than dealing with measures related directly to the phenomenon

itself. It is evident that the type of bases suggested thus far,

e.g., risk measures, are necessarily fairly abstract and tend to lean more to the subjective rather than objective side than is perhaps

defensible for incorporation into code documents that are of necessity

attempting to specify goals against which the attributes of a physical

system can be confidently measured. Even if the measures form only

the basis of possible provisions rather than the actual provisions

themselves, the question of confidence and subjectivity still arises.

Perhaps middle ground measures can be determined, but the nature of

such measures is currently unclear.

The conceptual difficulties involved in developing consistent measures for all hazard related provisions almost pall, however, in

comparison with the questions of implementation. In the first place,

it is evident that the levels of technical development in different

hazard research areas is very different, although their final

aspiration levels may be similar. The difficult question, therefore,

exists of whether or not to surge ahead in some of the more developed

areas--with the implicit dangers of a piecemeal approach--or to await

(but not necessarily idly) until all hazard-related methodologies are

at comparable levels of development, and then attempt to establish a code basis that is consistently applicable to all methodologies.

There are obviously relative advantages and disadvantages to both

approaches

.

It is suggested that a highly beneficial contribution that could

be made by governments or private funding agencies with the intent of

supporting innovation in building regulations as to sponsor research

designed to bring about a parity in the levels of technical expertise

present with respect to all building hazards instead of concentrating

on selected hazards.

A more pragmatic implementation question is the fact that, as the

technical sophistication of codes increase in response to increasingly

sophisticated design methodologies, the sophistication of those also

45
increase. This conflict cannot be easily resolved. The related point

that not all code controlled buildings necessarily involve

professional engineers in their design, nor should they, is also

relevant. A dual format code structure was tentatively suggested.

A point of obvious struggle that tends to underlie some of the

problems outlined above is that the building regulatory system is a manifestation of a socio-political decision rather than that of a scientific discipline.

Promulgating, maintaining and enforcing building codes are governmental and hence political acts. Not recognizing this

elementary principle is an error made surprisingly often by

individuals in both the building code field and scientific research

domains. The error can be disastrous, since it is only by recognizing

this elenemtal principle and following the lines of inquiry suggested

by it that there is hope that a more supportive relationship between

building control mechanisms and scientific methodologies can ever be

developed

Since building codes are political acts, they are also ultimately

societal acts. It is fundamental that society has the option of

pursuing approaches to its own well-being other than those we now have

or which are suggested by interest groups. It could be maintained,

for example, that the rush to impose the values of the scientific

community on the building code and hence society is not necessarily

any better in terms of the larger collective societal good than are values imposed by special interest groups such as trade unions.

Perhaps the strongest position that the scientific community has in

this respect is not necessarily one of the logic of their methods, but

simply that it appears that their methods are a surer way of

contributing to the collective good in the domains of health and

safety than are the methods of other biased interest groups. That

this is true, however, is not always as convincingly demonstrated as it should be. Too often changes are suggested that are apparently

based only on the firm conviction that science must be right and

nothing else. An obligation exists not only on the part of building

code officials to demonstrate that changes made are in the service of

the collective good, but with the proponents of change as well.

In any event society does have the right to choose its own course

in how it wishes to protect itself from building hazards even if the

methods chosen are radically different from those we either now have

or that are suggested by the scientific community. A role that

remains surprisingly unexplored for both the leaders of the building

regulatory mechanism and the larger research community (not

necessarily just the scientific community) should be to suggest,

monitor and evaluate all of the options available to society in a much

more extended socio-political context than is currently considered, so that society can indeed make informed choices about its own course of

action.

46
REFERENCES

1. deNeufville, Richard. "How Should We Establish Public Policy on Selling Design Codes or Performance Standards?" U.S. National

Conference on Earthquake Engineering Proceedings, Ann Arbor,

Michigan, June 18-20, 1975, pp. 327-336.

2. Ferguson, R. S. "Building Regulations: Problems of Tradition and

Knowledge," Journal of Architectural Research , Vol. 4, No. 2,

August 1977, pp. 17-40.

3. Krimgold, Frederick. "Alternate Design for Fire Protection," Fire

in Buildings Program, California sponsored by the University of

California, Cambridge, Massachusetts, September 1976.

4. McConnaughey , John. "Economic Impacts of Building Codes," Research

and Innovation in the Building Regulatory Process, National Bureau

of Standards Special Publication 473, U.S. Department of Commerce,

Washington, D.C., June 1977.

5. Schodek, Daniel L. "Effect of Building Regulations on Built

Environment," Engineering Issues, Journal of Professional

Activities, American Society of Civil Engineers, Vol. 102,

No. E13, Proc. Paper 12261, July 1976, pp. 293-300.

6. Starr, C. "Social Benefit vs. Technical Risk," Science , American

Association for the Advancement of Science, Vol. 165, September

1969, pp. 1232-1238.

7. Sweet, Justin. Legal Aspects of Architecture, Engineering and the

Construction Process , West Publishing Company, St. Paul, Minn., 1970.

8. Ventre, Francis T. "Dec is ion-Aiding Communications in the Regulatory

Agency: The Partisan Uses of Technical Information," Research and

Innovation in the Building Regulatory Process, National Bureau of

Standards Special Publication 473, U.S. Department of Commerce,

Washington, D.C., June 1977.

9. Wiggins, J. H. , Jr., and Moran, D. F. "Earthquake Safety in the

City of Long Beach Based on the Concept of Balanced Risk," Report,

J. H. Wiggins Co., Redondo Beach, California, 1970.

47

RESPONSE TO BUILDING INNOVATION

BY BUILDING CODES AND REGULATIONS

by

Steven Winter

President

Steven Winter Associates

Building Systems Consultants

New York, New York

The major U.S. building codes are updated intermittently (e.g.,

MPS issues updates as they are processed, BOCA issues supplements

annually, etc.). The States and other regulatory bodies which adopt

these codes do so sometime after the updates are issued. The result

is that there is a considerable time span for the process of:

recognition of the need for a code change; adoption of the code

change; revision of the code; adoption of the revision by regulatory

bodies; and implementation of the revision.

Innovations in the building industry, however, are constantly

occurring, and there is frequently no allowance in the language of

codes or in their interpretation for items not specifically

identified

.

The position of the author is that building codes and regulatory

agencies must be more responsive to innovative materials and methods

in order to foster, rather than hinder, improvements and efficiencies

in the building process.

Key Words: Building codes; code changes; incentives; innovations;

log homes; minimum property standards; model code

agencies; regulations.

49
INTRODUCTION

The major U. S. building codes are updated intermittently (e.g.,

MPS issues updates as they are processed, BOCA issues supplements

annually, etc.). The states and other regulatory bodies which adopt

these codes do so some time after the updates are issued. The result

is that there is a considerable time span for the process of:

recognition of the need for a code change; adoption of the code

change; revision of the code; adoption of the revision by regulatory

bodies; and implementation of the revision.

Innovations in the building industry, however, are constantly

occurring; and there is frequently no allowance in the language of

codes or in their interpretation, for items not specifically

identified.

THE POSITION OF THE AUTHOR IS THAT BUILDING CODES AND REGULATORY

AGENCIES MUST BE MORE RESPONSIVE TO INNOVATIVE MATERIALS AND METHODS

IN ORDER TO FOSTER, RATHER THAN HINDER, IMPROVEMENTS AND EFFICIENCIES

IN THE BUILDING PROCESS.

The following four case studies are cited as examples where

innovations in the building process have been both fostered and

hindered.

CASE STUDY 1: F.H.A. MINIMUM PROPERTY STANDARDS

1 . Background

A mid-West manufacturer of mobile homes and modular homes in

early 1977 submitted a group of its homes to the F.H.A. for

Structural Engineering Bulletin suitability.

The applicable standard was the HUD Minimum Property

Standards for One and Two Family Dwellings, 1973 Edition with

supplements

2 . The Innovation

The home manufacturer had developed a technique whereby

drywall ceilings were glued to the underside of ceiling trusses

rather than being nailed or stapled in the conventional way.

The drywall was laid face down on a horizontal jig and the

assembly of roof trusses was placed on top of the drywall sheets.

A jet of liquid urethane was squirted at the intersection of the

drywall surface and the truss-bottom-chord's face perpendicular

to it. Within a few seconds the urethane foamed up and formed a rigid weld fillet which firmly held the drywall to the trees.

Figure 1 indicates this detail.

50
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51
By this technique spackle-and-tape operations were greatly

reduced, fastener penetration of drywall was eliminated, there were significant savings in time, materials and labor, and the

integrity of the ceiling surface was maintained.

3. The Code

The Code did not specifically allow the use of adhesives in

ceiling applications, although the Code does state that "These

standards are intended to encourage the use of new or innovative

technologies, methods or materials. ... Alternatives,

nonconventional or innovative methods and materials shall

demonstrate, however, equivalent quality to these standards in

structural soundness, durability, economy of maintenance or operation and usability."

4. The Justification

The home manufacturer undertook extensive tests on the

process and additionally arranged for outside agencies to

undertake tests, including the following:

a . Underwriters Laboratories, Inc. :

1. Shear Resistance Tests for Ceiling Boards, UL1296

2. Aging and Temperature Cycle Tests on Foam.

b . Pittsburgh Testing Laboratory :

1. Shear Resistance Tests for Ceiling Boards, UL1296.

The structural tests met all requirements; the aging tests were still in process at time of writing but had retained an average of 94% of original strength in all tests, with the lowest

reading being at 81% of original strength in the 20-year

equivalency test.

These properties were adequate for the technique to be

accepted for use in mobile homes under HUD/FHA Mobile Home

Construction and Safety Standards and it was argued that although

these differed substantially from the MPS, it was an indication

of acceptance of the technique.

5 . Rejection of Technique

The Architecture and Engineering Division of FHA rejected

the technique and stated that conformance to the MPS was required, adding that:

52
"If you wish to use a new method of attachment for such a widely used product as drywall, we suggest that you secure:

(1) acceptance of the method by industry and by the model

codes, and (2) inclusion of the method in the American

National Standards Institute (ANSI) Specification A 97.1.

We will then be in position to consider the suitability of

the method for use under HUD/FHA housing programs."

Conclusions

It is not clear whether the FHA action was in keeping with

the code intent to "encourage the use of innovative methods," nor

is it clear if the FHA instruction to secure acceptance by other

bodies was a valid requirement to determine equivalency to MPS

standards

.

It does seem, however, that the home manufacturer did

exhaust many if not all avenues of actual materials testing

procedures and that it might have been incumbent upon FHA to:

a. Accept these test results as proof of equivalency to MPS

standards, or

b. Suggest alternate or additional tests which would prove

equivalency.

Suggesting acceptance by other agencies as a basis for

consideration for acceptance by FHA appears to be more of a hindrance than a help to the innovative technique.

CASE STUDY 2: UNIFORM BUILDING CODE/

CORPS OF ENGINEERS STANDARDS

Background

In 1973 the U. S. Army Corps of Engineers administered the

procurement of housing under the U. S. Air Force Industrialized

Construction Program. The procurement included the delivery of

relocatable modular dormitory buildings to house 1,188 men at Air

Force bases in Delaware, Virginia and Florida.

The modular dormitory units, similar to motel units, were produced by a manufacturer in upstate New York. The modules were built with a frame of light-gage steel studs, joists and rafters,

to which plywood and drywall sheathing were glued and fastened.

The applicable standard was a performance specification

issued by the Corps of Engineers, which included references to

the Uniform Building Code, 1970 Edition, as well as to

publications of the American Institute of Steel Construction.

53
Figure 2: Air Force housing module. Sidewalls have

sheathing only on inner face of steel studs.
2. The Innovation

The manufacturer had determined, based on advice from

architectural/engineering consultants, that the walls of his

modules were remarkably strong due to steel studs with sheathing

both sides and due to doubling up of walls as modules were placed

side by side.

The manufacturer decided to eliminate the outer skin of

sheathing from each of the side walls, such that the steel studs

had sheathing of 5/8" drywall on one side only. Tests and

calculations by the manufacturer verified that this technique

maintained the structural integrity of the units.

This technique resulted in savings of approximately 240,000

sq.ft. of plywood sheathing. Due to the Value Engineering clause

of the contract, both the manufacturer and the Air Force stood to

benefit from the innovation.

3. The Code

Neither the specifications nor any of the referenced codes

or publications dealt with the use of light-gage steel studs

which had sheathing other than on both sides. Related

literature, journals and text books were researched but there was

no basis on which the Corps could approve the structural analysis

presented by the manufacturer and his consultants.

4. The Justification

The Corps agreed to a testing program in which 8 ft. x 8 ft.

sections of wall were subjected to shear/racking and aerial

loading tests. Figure 3 shows the test sample under load.

The tests were completed in a timely manner, according to

applicable ASTM procedures and witnessed by the Corps.

5 . Acceptance of Technique

Despite the lack of precedent or reference, the Corps

approved the procedure without interrupting the construction

schedule

.

6 . Conclusions

Here was an instance of a highly structured organization,

with extremely complex codes, standards and procedures, the U. S. Army, moving with due speed to evaluate and approve an innovative

building technique which resulted in tangible benefits to both

the manufacturer and the Government.

55
This procedure clearly fostered improvement and efficiency

in the building process.

CASE STUDY 3: BOCA BASIC BUILDING CODE

1 . Background

A number of East Coast States have adopted the BOCA Basic

Building Code as a statewide standard to which all factory

produced homes must comply. Compliance is usually monitored by

inspection of components and procedures inside the manufactorers

facilities by independent third party inspection agencies. The

intent is that all aspects of the house not able to be inspected

on the site due to their being hidden from view are inspected at

the plant after installation but prior to being hidden.

Conventional construction in these same States sometimes

falls within different code jurisdictions, depending on the

statutes in force in the local town or county. In any event, all

conventional construction is theoretically inspectable at the

site and none of the independent inspection agency requirements

apply.

This case study focuses on a hybrid situation, a manufacturer who precuts components in a factory after which they

are assembled on-site, and who maintains that everything is

inspectable at the site.

2 . The Innovation

The manufacturer produces precut post and beam components

which are assembled on site. To this structural frame are attached pre-assembled panels consisting of sheathing on both

sides of a core of urethane foam, see Figure 4. The panels are not load bearing except for their own weight and for local loads;

they contain no electrical, plumbing or other services or inserts. The panels do provide the wall insulation and the

interior and exterior finish.

3 . The Problem

It appears that in some BOCA code jurisdictions, building

officials are considering whether they should impose a requirement on the manufacturer to undergo independent third

party inspection of his panel production.

Their argument is that the insulation is factory installed

and not able to be inspected on site.

56
57
The manufacturer argues that his panel is a pre-cut non-load

bearing panel and, like an insulated entrance door, should be

allowed to come to the site without undergoing an inspection

program. The manufacturer has undertaken structural and heat

loss tests of his panel and has received BOCA approval for it as

a component.

The matter is still not resolved. However, if forced to

incorporate a third party inspection program into his operations,

the manufacturer will probably abandon his process and laminate

one skin of his panel onto the core at the site, thus exposing

the insulation to view.

4. Conclusion

In this case the enforcement agency rather than the code

itself, is at the center of the dilemma. The manufacturers'

situation falls into a grey area and it is not clear as to

whether he is or is not hiding components from the on-site

building inspector's view.

Whatever the outcome, it is hoped that the enforcement

agency will find a way to approve the manufacturers' system such

as to assist in the incorporation of innovative techniques.

CASE STUDY 4: CODE ASPECTS OF LOG HOME CONSTRUCTION

1 . Background

Log homes were introduced to the United States in 1638 and

have been an inherent backdrop to the development of this

country's history.

In recent years, there has been a resurgence of activity in

the construction of log homes. Many of these are produced by

factory pre-cut techniques and the most advanced engineering and

production methods.

Despite its place in history, this construction technique

has recently encountered problem areas with a number of building

codes and standards.

2. The Problem

The major problem has been in the area of energy insulation.

Many energy insulation standards have been promulgated in the

past two years, some of them prescriptive but most performance

oriented, such as the highly effective ASHRAE 90-75.

58
The New York State Public Service Commission, for example,

issued its Energy Insulation Standards to become effective April 1,

1977. These included a requirement for a maximum wall U-value

of .07 (or R = 14.29), but allowed for compensatory insulation

such that any deficiency in the wall could be compensated for by

insulation in excess of the minimum in other house components,

such as roof, floor and openings.

None of the eight producers of log homes whose wall

insulation values we have analyzed (see Tables 1 and 2) meet the

P.S.C. requirement; all have to compensate in other areas,

resulting in very heavily insulated roofs, floors, etc.

The Farmers Home Administration on March 21, 1977, issued

its proposed rules on Insulation Standards. These were prescriptive standards calling for maximum wall U-values of .05

(or R = 20) , which no log home producer could meet with current

construction techniques.

Yet in actual energy usage, tabulations and energy loss

tests, log homes perform far better than the calculations say

they should, generally by a factor of some 25 percent.

This wide discrepancy between calculated and actual heat

losses has long been acknowledged by engineers, but not fully

identified; nor qualified, and never fully considered, in

building codes.

Even the most thorough building codes only list partial

requirements

:

a. Heat conductance by virtue of U-values.

b. Convection losses through infiltration.

But there are other, important criteria whereby heat is lost

or not lost in homes, and specifically in log homes.

a. There is a mass factor inherent in solid logs. This factor

reduces heat loss due to the bulk of the material and is

evident in brick, stone and concrete walls.

b. Log walls have surface shape and texture which absorb and

re-radiate heat from both the sun and from internal heat

sources. This "heat retention" or "resistivity" quality is

clearly evident when you touch a log wall on a winter night,

but is not presently qualified in any codes or standards.

c. Solid wood walls do not contain any insulation other than

their own, highly effective, insulative values. Therefore,

there is no possibility of breakdown of insulation

performance due to moisture penetration, dust saturation,

material settling, non-filling of insulatable space, or other construction defects.

59
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64
d. Solid log walls make use of surface and baseboard electric

and utility raceways and outlets. So, there are no electric

outlets, junction boxes, etc., which penetrate the wall.

These penetrations have been responsible for about 20% of

the heat loss due to infiltration which itself is

responsible for 25-40% of all heat loss in framed homes.

e. Most calculations assume that the outdoor temperature, -20°F

or whatever it is, is constant during the whole day. This,

c of course, is not so. Moreover, the interior need for heat

fluctuates widely over a 24-hour period.

The resulting temperature gradient between interior and

exterior is a totally different picture from the one suggested

by constant U-value requirements.

In other words, it might be that a home needs a wall factor

of:

R - 16 for 1 hour a day

R - 10 for 8 hours a day, and

R - 4 for 15 hours a day.

And we suggest that the optimum value should be the goal,

not the maximum value.

f. And a number of unanswered, unresolved phenomena, none of

which are identified in insulation standards in most

building codes.

3 . Conclusion

In this instance it appears incumbent upon the Log Home

industry to develop a program to research, develop and gain

approval for evaluation procedures to more accurately ascertain

the true thermal performance of log homes. Ultimately it will be

the code promulgating agencies' position to approve these

procedures and it is hoped that this "re-innovative" building

technique will not be hindered by such approvals.

CONCLUSIONS

Building code agencies and their personnel can be responsive to

innovations in building but are frequently not so.

I believe that a key reason is that there are no incentives for an agency inspector or engineer to stick his neck out by approving an innovative technique. Nobody was ever fired for rejecting an application for approval of a new product "subject to receipt of

additional data." One can always find an additional item to require.

65
The degree to which innovations are evaluated is becoming more

complex and the thorough evaluation of new techniques is usually fully

justified. And indications are that things are not too bad after all.

New products and techniques are being approved even if they are not

being approved as quickly as some people would like.

In a world economy based on finite resources, innovation is not

optional. It is imperative. Building codes and regulatory agencies

must be highly responsive to such innovations in order to play their

part in the improvement of the building process.

66
A CONSULTING ENGINEER'S VIEW OF BUILDING CODE

PROCESS FROM CONCEPTION TO ADOPTION

by

Norman J. Kornsand, P.E.

Assistant Vice President

Rolf Jensen & Associates, Inc.

Deerfield, Illinois

The author has been attending the meetings of the model code groups

for the past several years. During that time period, he has observed

the process, noted the changes that are taking place in the process,

identified forces responsible for the changes, analyzed the problems

and has formulated possible areas to refine, streamline and be more

efficient in the building code promulgation process.

The paper will present the building code process from the standpoint

of the designers and engineers who must work with its provisions. The

paper will show a significant trend in the past few years that is complicating the process. This includes more code changes, more complex code

changes, expansion of the codes into more areas of control, and attempts

to keep pace with the plethora of new products, devices and designs

flooding the building materials market.

Key Words: Building codes, due process; legislation; model codes;

promulgation; regulatory process; standards development.

67
INTRODUCTION

Laws and Regulations have become as American as apple pie. As

this country's standard of living has increased, so has the amount and

complexity of rules and regulations. The building code regulatory

process is part of this evolution. It has not been that many years

since building code provisions necessary to assure public safety and

welfare were a succinct set of prescriptive rules that were easily

formulated and understood. But that is ancient history and we are concerned with today and tomorrow.

The times are changing and the model building code groups must

adapt to avoid obsolescence or outside legislative regulation. One

indication of this is the proposed Senate Bill 825 which is entitled

the "Voluntary Standards and Accreditation Act." If passed, the

federal government will be directly involved in the supervision of

voluntary standards development through the Federal Trade Commission

and a new agency, the National Standards Management Board. The

current privilege of promulgating concensus model codes would be

tightly controlled by Washington.

This paper discusses three basic topics. First, the present

model building code promulgating process has not adapted itself to

cope with the changing technical and sociological atmosphere in which

it operates. Second, the process as currently operating does not

adequately represent due process, or public exposure. Third, possible

alterations to the code process will be presented which could help to

alleviate the problems discussed. While not totally encompassing or collectively exhaustive, these procedural changes are indicative of

the possible changes that could be implemented.

These three topics will be from my point of view as a consulting

engineer specializing in fire safety and building code related

subjects assisting architects and engineers on building design and

construction. Because of our business, we are active participants in

the building code promulgating and regulatory process and have

observed changes taking place and their consequent effects.

THE CODES ARE EXPANDING

Prior to addressing any issue, it is necessary to identify the

magnitude of the situation. Based on the number of printed words.

Figure 1 graphically depicts the growth in the Uniform Building Code

since 1970.

Also based on the number of words, the 1977 supplement to the UBC

(which covers a one year period) is 76% the size of the 1975

Accumulative supplement (which covered 2 years).

On the average, the 1977 changes are 52% more than either the

1974 or 1975 changes. Therefore, not only are the codes getting

larger, the number of approved changes each year is expanding.

68
69
Obviously, not all changes submitted for consideration are approved. The number of changes submitted to the BOCA Basic Building

Code for each of the past 6 years is shown in Figure 2. The number of

changes in this short period has tripled.

The Standard Building Code of the SBCC in 1976 had 214 changes

submitted compared to 250 in 1977. This is a 20% increase in one year

In each of the three model building code groups, the committees

charged with making recommendations for approval, disapproval or further study must analyze each change and hold open hearings to discuss each and every submission. With more changes being submitted

each year, the committee members must devote more time to this

voluntary effort or each item must receive less attention. In all

likelihood, some or each has occurred; but with continuing increased

workloads, it is likely that less attention will be given to each

item. This is undesirable.

Of the 1977 submissions to BOCA, there are 11 different submissions to Section 431, 13 to Section 6l6, 14 to Section 1202 and 14

to Section 2102. In addition to considering each, the various

proposals need correlation to remove duplication, compatibility, and

preferred wording. This translates into either more time or less

attention to detail.

The 1977 submissions to BOCA contain 50 new items for inclusion

into the Basic Code, while there are only 27 items for deletion

without substitution; almost a two to one ratio. This shows a widening in the scope of building codes. Examples of totally new

items introduced into the model building codes since 1973 include provisions for high-rise buildings, foamed plastic insulation, energy

use, handicapped access and egress and historic buildings. It should

be obvious that the task ot creating, reviewing and modifying a building code is becoming more time consuming, more complicated and more

difficult.

RECENT CHANGES IN THE PROCESS

How have the model code groups handled the additional and more complicated work load? One method that has been utilized by BOCA and

ICBO is the "consent calendar." By this method, once an item has been

recommended for approval, disapproval or further study by the main

code changes committee, the item is not debatable at the annual

meeting unless specifically challenged in writing by a specified date.

This frees time at the annual meeting for discussion of items that

individuals or groups feel is of extreme importance, and need

additional consideration before action is formalized. This process

helps to expedite the proceedings at the annual meeting, but does not

alleviate the committees or subcommittees work load.

Committees and subcommittees have been experiencing the work

expansion that we have discussed. This has forced more meetings into

70

longer duration and into evenings. The devotion of more and more time

to the code process has an upper limit. The costs of attending more

and longer meetings can become an unbearable expense. These expenses

do not only include the costs of transportation, lodging and meals;

but also the cost of time, which is the most precious.

Since proposed code changes are multiplying and expanding in both

breadth and depth, additional ad hoc and subcommittees are being

formed to handle the added burden. This entails even more meetings

and results in more time and expense to the members and other

attendees

WEAKNESSES IN THE SYSTEM

Thus far, we have addressed only the external forces that have

complicated and compromised the model building code promulgation

process. As a regular participant at model code group meetings, 1 have observed many internal forces that have contributed to the

present situation.

In all of the meetings, agenda items are discussed in the order

in which they would appear in the code. With human nature what it is,

early items receive a considerable degree of discussion and items from

the later chapters are often rushed through without adequate

discussion and consideration. Every chapter and section of a building

code is important and each submission needs due process, public

exposure and deliberation.

Another human foible is the "more is better syndrome." It works

like this; if one additional exit is good, two is undoubtedly better.

The problem with this philosophy is that it ignores the harsh reality

that the designer and owner must recognize--that extras cost more money and this cost must be evaluated based on the utility or need of

the item. There have been many code officials who have told me that

economics do not count and that the code is written to safeguard the

public. This is only partially true. The code is written to insure

public safety by establishing minimum performance or specification as stated in each of the model code documents. The codes are not

directed towards prescribing or establishing the ultimate. With

building costs escalating ever upward, the code making groups must

consider all proposed changes from a cost-benefit standpoint and only

approve those changes that are really necessary to insure an acceptable level of safety. The code making process should not

isolate itself in a vacuum while ignoring the impact on the design and

construction industry. The codes are prepared to regulate building

construction and should always recognize the impact of any code

provision.

With the building codes becoming more complex and detailed, it is

desirable to have groups and individuals with expertise on all

specific issues participate in the process. The entire procedure has

become too elaborate for generalists. It is impossible for any single

individual to be fully informed on every topic that is part of the

code. However, the committees do not always appear to be formed from

72
their expertise on the subject. Often, committee members are forced

to make a decision on items they really cannot fully analyze. It is

cumbersome to educate the committee members in order to present a proposed code change. This slows down the process and leads to

decisions based on limited subject knowledge.

At present, the only voting members of the model building code

groups are building officials. Fire officials are normally excluded

from voting; and trade associations, designers, architects, engineers

and manufacturers have a voice but no vote. By their respective

constitutions, the code groups only represent a concensus of building

code officials. Also, each jurisdiction is entitled to one vote and

all votes bear equal weight. Therefore, the State of Indiana's vote

in ICBO has no more impact than the vote of Kalamazoo, Michigan, or Livermore, California, even though population, number of building

permits or value of construction is different by several orders of

magnitude. The philosophy of 1 man--l vote is not followed.

Another situation is the "haves and have nots . " The larger and more affluent companies and trade associations can afford the time and

expense to devote to the building code making process. Others cannot

afford the investment. Consequently, those that can afford the effort

are regularly heard and listened to, while the small guy does not have

the same opportunity.

It is desirable for trade associations and manufacturers to be

present and represented at the code meetings. However, there is a problem. The individuals who represent industry are there for the

benefit of their firms or affiliated companies and, therefore,

represent vested interests. These representatives are quite

knowledgeable to their field, but since they attend the meetings for

specific purposes; they obviously present the more favorable view of

their employers. It becomes necessary for the committee members to

review the data submitted by all parties in the proper perspective.

Unless both sides of an issue are properly presented, this can be a difficult task. Industry and trade associations are beginning to

realize that their effectiveness is enhanced by a completely objective

presentation of the facts. This is partially due to the influences of

legal decisions in the area of product liability. While objective

presentation approaches the norm, there are still several interests

that persist in presenting arguments based on unsupported, distorted

or emotional information or on data taken out of context.

POSSIBLE GOVERNMENT REGULATION

Senate Bill 825 makes several contentions. The first is that

government must protect the public. This implies that the current

model building code system does not. To rebut this argument, it must

be shown that the current voluntary code making process, as one of its

principle purposes, provides this service. This can only be

effectively demonstrated by showing how all aspects of society that are affected by codes and standards, have been included in the decision

making process and that the final product--the code or standard--has

73
evolved through democratic due process with the proper checks and

balances

Another allegation is that the system fails to develop needed

standards. The model code groups must prove that once a need is

identified, the mechanisms are provided to develop the necessary

regulatory provisions in a streamlined manner.

The bill also contends that the process includes adverse effects

on competition. This can only be refuted by proving that meaningful

participation by all affected parties is actively recruited and

welcomed in the code groups

The "findings of fact" in the bill question the due process of

the code groups. This issue not only addresses the ability to be

listened to, but also that adequate time and thought is given, and

that the decisions are made by a representative jury. This indicates

that committee membership and voting rights must not be vested

exclusively in the enforcing agencies.

The bill states that the code process "can be a means for

widespread consumer deception." The best counter-argument is once again to demonstrate the active and meaningful participation of all

affected interests.

It is also contended that the "code process poses grave economic

hardships for small business concerns." This is a tough one to defend

against for any privately funded organization, especially considering

the necessity to maintain due process. In essence, the bill is saying

that government is the only vehicle available to protect small

businesses. To protect small businesses, code making must be

streamlined to permit any size firm the opportunity to be equally

represented at the decision making levels.

There are other arguments presented in SB 825, but they directly

relate to the points that I have enumerated. This legislation did not

originate in a vacuum. It was created for many of the reasons that

have already been discussed. The prognosis is clear; unless the code

making bodies start initiating changes, the government may take over

the entire process for the purported purpose of providing protection

to the public.

POSSIBLE CHANGES

The need for change has been expressed from the standpoint of

internal and external influences to the model code groups as well as the eminent threat of government intervention. The final segment of

this treatise will be to identify some possible ways change could be

introduced.

The voting procedure could be changed. Instead of a single vote

per jurisdiction, the voting by code officials could be based on population, square footage of buildings or some other more equitable

74
base. Voting could be set up for approval or disapproval or an action

by the various committees without the ability to amend. Committee

membership could be comprised of code officials, fire officials,

manufacturers, architects, engineers, consumer groups or other

interested representatives; some subcommittees are now. In this

manner, committees could be comprised of individuals with specific

expertise in the scope of work covered by each committee. Additional

committees would have to be formed and some mechanism would have to be

provided to appoint committee members. The appointments could also be

subject to an approval vote of the code officials. Due to the cost of

attending meetings, the voting could be conducted by mail. With the

proposed change in the weight of each vote and the difficulties in

tabulation, this would be a necessity. The disadvantage would be the

inability of some of the members to discuss each committee

recommendation in an open forum. Since supporting documentation would

have to be provided to each voting member and other interested

parties, increased printing and postage costs to the code groups would

result.

Another streamlining method would be to place a time limit by

which a committee must take affirmative action on a subject. Assuming

a two year limit, the committee must recommend approval, approval as revised or disapproval within two years after submission. A

recommendation of further study could not be made beyond two years.

The problem with this proposal would be the tendency to have a committee recommend disapproval of an item having merit simply because

time is expiring. Close control on committee membership, agendas and

meeting dates could help alleviate this. In conjunction with this

proposal, the committees would discuss proposed changes based on the

date of submission and not based on the section of the code. This

would need to be tempered when similar changes or related changes are proposed at later dates. The responsibility for the coordination of

the agenda items would be by the staff of the code groups

.

To insure that the agenda is fully covered in a scheduled meeting

time, time limits for arguments could be established. As an example,

the proponent of a change could be allotted 10 minutes for

presentation with each opponent given 5 minutes. The proponent may

then be given 5 minutes for rebuttal. Not more than one individual

from any group or jurisdiction could speak on the same item. While

time limits of this nature are constraining, they could be

instrumental in guaranteeing each submission a respectable hearing.

To limit the expenses involved in attending the various code

meetings, "committee weeks" could be scheduled where several

committees could meet during the same week. Unrelated committees

could meet simultaneously while related committees could meet back to

back. By judicious scheduling and preprinted agendas, individuals

could attend those portions at each committee that have specific

interest. Meeting locations should be as centralized as possible and

arranged to provide maximum exposure, not just to be convenient for a single or group of committee members. This would require increased

coordination by the staff of the building code groups in scheduling

meetings

.

75
There is significant duplication of effort between BOCA, ICBO and

SBCC. Efforts have been initiated to consolidate the three groups

through the establishment of CABO and BCMC, but increased effort is

desirable. As an ultimate goal, the work done in developing three

different codes could be combined to establish a single concensus model building code. This could possibly be done by dividing the

issues. As an example, ICBO could be given full responsibility for

fire suppression and alarm, BOCA could take exiting and SBCC could

have full charge of fire resistivity. Through this approach, the

duplication of effort could be eliminated and a single nationwide

building code could be promulgated without government intervention.

CONCLUSIONS

The pattern is very clear:

o The codes are expanding in breadth and depth.

o The number of proposed changes each year is growing.

o Building design and construction technology is becoming

more sophisticated.

o The Federal government is concerned about the

objectivity and representative nature of the current

system.

The model building code groups have not streamlined their

procedures to keep pace with the rapidly changing environment. By

their structure, they have excluded many segments of society that

should be included in the code process. In other words, there has not

been adequate "public exposure." The procedural regulations and

qualifications for voting can be challenged as not representing "due

process .

These problems are being scrutinized by consumer advocate groups,

private individuals and the federal government.

The system that was devised several years ago has become cumbersome

and may be non-responsive to the needs of the late 1970' s, unless the

model building code groups develop change from the inside, it may be

forced from the outside.

76
STANDARDS/CODES FOR ENERGY CONSERVATION

IN LIGHTING DESIGN

by

Robert L. Smith, P.E.

Associate Professor of Architecture

Department of Architecture

University of Illinois

Urbana, Illinois

There is a general agreement on the need to eliminate unnecessary

energy use in providing artificial illumination for buildings.

However, there is widespread disagreement on the procedure that should

be promulgated to achieve that need. This paper suggests a method to

evaluate building standards/codes and compares three procedures

developed to achieve energy efficient lighting systems. The

procedures compared are (1) a standard developed by the Illuminating

Engineering Society and published as Section 9 of ASHRAE Standard

90-75; (2) a guideline published by the General Services

Administration; and (3) a code being developed by a State building

code commission.

Key Words: Artificial illumination; buildings; criteria; energy

conservation; energy consumption; environmental design;

lighting levels; standards.

77
There is a general agreement on the need to eliminate unnecessary

energy usage in providing artificial illumination for buildings.

However, there is widespread disagreement on the procedure" that

should be promulgated to achieve that need. This paper suggests a method to evaluate lighting standards/codes and compares three

procedures developed to achieve energy efficient lighting systems.

The procedures compared are (1) a standard developed by the

Illuminating Engineering Society and published as Section 9 of ASHRAE

Standard 90-75; (2) a guideline published by the General Services

Administration; and (3) a code being developed by a State building

code commission.

During the past year most governmental units having regulatory

control over building construction have directed their attention to the

use of energy in buildings. In many cases they have enacted, or are considering legislation that would result in the reduction of energy

use in existing buildings and/or control the design of new buildings

so that the potential for energy conservation will be greater.

This paper will examine procedures that have been developed to achieve

a reduction in the energy used for providing artificial lighting in

buildings. In conducting this evaluation, first, a set of criteria

will be proposed; secondly, the alternative procedures will be

identified; third, the procedures will be examined by the criteria;

and finally, a summary and conclusion will be presented. The validity

of the comparisons is dependent on the comprehensiveness of the

evaluation criteria. Therefore, special attention must be given to

the instrument that is suggested for use in the evaluation, for if

this instrument is valid, we will have taken a giant step toward

selecting the appropriate procedure.

EVALUATION CRITERIA

In establishing a method for evaluation of a procedure, the first

test would be to check the universality of the method, i.e., the

substratum on which it is built must provide a commonality for

evaluating any procedure. It is proposed that the appropriate method

would begin with the three rudimentary criteria: effectiveness,

propriety, and applicability.

Evaluating the effectiveness of a procedure would determine how

successful it will be in achieving the stated objectives. There is no attempt here to determine the validity or comprehensiveness of the

objectives. For example, the procedures examined address only the

subject of energy consumption and do not relate to the use of resources. The criteria is presented for evaluating a procedure--not

the political, moralistic, or technical factors from which it evolved.

Further subdivision of effectiveness would include the components

energy and power as evaluation criteria.

The documents that may be examined are often given different

technical names such as standards, guidelines or codes. The term

"procedure" will be used in a generic sense to include all of these

documents

78
A test of the propriety of a procedure would examine how well it

addresses the psycho-physiological needs of people. This converts to

the basic criteria for examing any environmental design, i.e., does

the design address the image, activity, and technology requirements of

the environment?

The applicability of a procedure is a most important criteria.

If it can be implemented with fairness and consistency without

generating significantly negative implications for any of the major

members of the building community then, and only then, can an optimistic prognosis be made for the success of the procedure.

Effectiveness

Energy : The energy consumption in buildings begins with the

energy consumed in the production of the components that are used to

construct the building. Research conducted by Hannon, et al has,

for example, indicated that the enea^jgy embodied in a standard steel

system floor bay is 292,723 Btu/SF , whereas the energy, embodied in

a reinforced concrete system floor bay is 172,021 Btu/SF . Although

data on all components is not yet available, a standard should

encourage optimum energy embodiment in components .

The basic definition of energy in effect stipulates that to

achieve reduced energy consumed in lighting conditions must be imposed

to control the time of operation. Available control systems may be

classified as manual, semi-automatic, or automatic. Manual control

systems are totally dependent on human behavior for operation and are thus unreliable as energy conserving techniques. At the other

extreme, automatic controls are usually preprogrammed based on predicted operational sequences and depending on the sophistication of

the system, may or may not maximize energy reduction. Semi-automatic

control systems usually require manual initiation of the operation

which can be terminated either manually or automatically. A

semi-automatic control system in a room would require that an occupant

turn on the lights, and would permit the occupant to extinguish the

lights upon leaving, but would automatically extinguish the lights

should they inadvertently continue to operate. Thus, for a procedure

to be effective in energy reduction, it must require minimum energy

consumption by a lighting system which can be assured only by the

inclusion of semi-automatic, or a very sophisticated automatic control

system.

Power : A procedure that restricts the power demand would limit

the energy consumption that could occur. In any operation the energy

use would be limited by the power rating of the connected load. This

has the effect of not only establishing a maximum energy use for

continuous operation, but also limits the demand at any point in time.

As the use of a space changes, the lighting requirements also

change. In a classroom for drafting instruction the possible visugl

activities may require 30, 70, or 100 footcandle of illumination.

Therefore, an effective procedure provides for reduced power demand

with activity change .

79
Propriety

Image : Determining if a procedure is proper involves evaluating

subjective as well as objective requirements. Although increased

energy conservation might be achieved if no accommodations were made

to enhance the image of a space, there are situations where this

policy would seem over restrictive. When justified, lighting should

be designed to accommodate the needs of architectural form achieve - ment and color rendition requirement .

Activity : Buildings are conceived, designed, and constructed to

provide an environment for achieving stated goals. These goals, with

few exceptions, can be classified in terms of their visual

requirement. Thus, it can be concluded that a properly designed

lighting system will accommodate the varying visual acquity of users,

the relationship between quality of light and activity achievement,

the requirements for public health and safety , and the needs for

security of property.

Technology : Often situations arise where the most energy

efficient item or design is not desirable under the extenuating

circumstances. For example, where difficulty of lamp replacement

justifies long life, or where lighting needs are minimal such that a small source is desirable, or where the heat of light impacts the

heating or cooling system, or where ambient conditions are extreme. A

proper lighting system design should acknowledge constraints of

methods and materials , and properly interact with other building

systems .

Applicability

Implementation : To be conducive to fair and consistent enforce - ment , a regulation must be written in understandable language that can

be understood and interpreted with a high degree of predictability.

This statement would seem to limit regulation to the prescriptive type

of instrument. However, the intricacies of performance-oriented

instruments may be mastered if the need for education is recognized

and proper training conducted.

Implications : The building community consists of a highly

diverse group of participants, including manufacturers, distributors,

designers, contractors, regulatory agencies, unions, owners, users,

and many others. For maximum effect, a procedure would encourage

innovation and research by these participants and should not

significantly increase the life cycle cost of constructing, owning and

operating a building.

80
Energy

encourages optimum energy

intensity of components

requires minimum energy

consumption by lighting system

EFFECTIVENESS

Power

restricts power demand

provides for reduced power

demand with activity change

Image

accommodates architectural

form achievement

accommodates color rendition

requirements

accommodates relationship

between quality of light and

activity achievement

accommodates relationship

between quantity of light and

activity achievement

PROPRIETY Activity

accomodates varying visual

acuity of users

accommodates requirements for

public health, safety and

welfare

accommodates need for security

of property

-

Technology

acknowledges constraints of

methods and materials

acknowledges interaction with

other building systems

Implementation

inducive to fair and

consistent enforcement

APPLICABILITY

Implications

encourages research and

innovation

increases life cycle cost

81
PROCEDURES

This author has made no attempt to collect all the procedures

that have been developed but has selected prototypes representing the

different basic techniques. The procedures selected are:

ASHRAE Standard 90-7|s "Energy Conservation in New Building

Design." Section 9 , this document was developed by the

Illuminating Engineering Society who also published the lighting

standard in a separate document "lES Recommended Lighting Power

Budget Determination Procedure EMS-1." (Subsequently referred

to as "Procedure EMS-1.") (See Appendix 1.)

General Services Administration "Energy Conservation Guidelines

for Existing Office Buildings." Prepared by the GSA staff in

cooperation wLth the AlA Research Corporation and selected

professionals. (Subsequently referred to as "Procedure GSA.")

These guidelines were chosen, even though they specifically apply

to existing buildings, because they are more comprehensive than

earlier GSA guidelines. (See Appendix 2.)

State Lighting Code: a procedure being developed by a State

building commission. This code has not been enacted; thus it

would be inappropriate to identify the State. (Subsequently

referred to as "Procedure S.")

PROCEDURES EXAMINATION

Energy

Procedure EMS-1: no attempt is made to regulate energy

embodiment in components; minimal requirements are included for manual

switching (Section 8.5); proper lighting controls are suggested

(Section 9.2.2); suggestion for circuiting, switching, or dimming

includes the provisions for reduction of lighting to 50 percent level,

turning off all lighting when space is empty, and manually or automatically dimming for daylight utilization (Section 9.52).

Procedure GSA: no attempt is made to regulate energy embodiment

in components; separate, convenient switching and switching to utilize

daylighting is suggested (paragraph C-7); circuiting for 5 watts per

sq. ft. suggested (paragraph C-11); need for adequate circuiting and

proper controls, including automatic controls, detailed (paragraphs

G-1, 2).

Procedure S: no attempt is made to regulate energy embodiment in

components; each enclosed area required to have separate switching;

areas over 500 sq. ft. must have 50 percent lighting level control;

switching to utilize daylighting required; switches must be readily

accessible; task lighting to include switches at each location.

82
Power

Procedure EMS-1: Maximum allowable power budget (limit) for

building is determined according to visual activity in various spaces

(Section 9.2): Lighting design is completely independent of budgeting

procedure; achieving varied power levels for varying tasks

responsibility of designer; designer encouraged to design for less

power than limit allows (Section 9.2.2).

Procedure GSA: a power goal of 2.3 watts per sq. ft. of net

rentable space is set; multiple lamp luminaires with integral switches

suggested for varying need (paragraph G.l.c).

Procedure S: maximum of 3 watts per sq. ft. set for spaces with

critical visual activity; 1 watt per sq. ft. for spaces with no visual

activity; .5 watts per sq. ft. for corridors, etc.; portable lights,

suggested for increased visual needs, are not included in power limit.

Image

Procedure EMS-1: power for highlighting added to budget (Section

9.3.4.2.b); lamp of lower efficacy may be used where color rendition

is important (Section 9.3.2.1).

Procedure GSA: no allowance is made for image achievement.

Procedure S: no allowance is made for image achievement.

Activity

Procedure EMS-1: designer charged with responsibility to provide

effective visual environment (Section 9.2); budget determination

includes varying quantity of light for activity achievement (Section

9.3.1); budget determination stimulates luminaire coefficient of

utilization based on need for quality lighting (Section 9.3.2.2);

health, safety, and welfare needs are responsibility of designer

(Section 9.2); budget determination allows for exterior security

lighting (Section 9.4).

Procedure GSA: suggested quantity of light is determined by

using a visual difficulty rating which is given for several tasks,

multipled by hours per day task is to be performed, adjustment factor

included for defective eyesight (Paragraph D.2); quality lighting is

recommended and instructions given for achieving ESI (Equivalent

Sphere Illumination) (Paragraph D.l); no specific allowance made for

lighting for health and safety, and no exterior security

recommendation made (Paragraph H.l).

Procedure S: higher watts per sq. ft. budget is allowed for areas of greater visual needs, actual achievement is designer's

responsibility; no reference made to health and safety, or security of

property; however, budget allowance is given for each linear foot of

building exterior.

83
Technology

Procedure EMS-1: budget allowance made for installations not

permitting source of highest efficacy (Section 9.3.2.1); surface

reflectances and light loss factor specified for budget purposes but

exceptions are allowed (Sections 9.3.3 and 9.3.4.3); designer

encouraged to interact with other energy needs (Section 9.2.2);

designer encouraged to use lamps of higher efficacy and more efficient

luminaires (Section 9.2.2); inefficiency of lighting smaller rooms compensated for in budget procedure.

Procedure GSA: suggestions made for achieving good design but no specific variance for technology limitation (Section C) ; interaction

with other systems encouraged (Paragraph C-9).

Procedure S: no acknowledgement of technological constraints or need to interact with other systems.

Implementation

Procedure EMS-1: Budget prepared based on planned, or intended,

activities in space, list of specific activities and number of work

stations must be determined before budget preparation; budget requires

calculations for each space; many variables possible, designers and

enforcers will need familiarization or training.

Procedure GSA: Power limit of 2.3 watts per sq. ft. rentable

space, only criterion for compliance.

Procedure S: area of each individual space must be determined

and general activity to be performed in that space; budget based on

area and watts per sq. ft.

Implications

Procedure EMS-1: Requires designers to follow lES guidelines

more closely; eliminates temptation to misuse recommendations ; need

for detailed study of visual activities in building should result in

earlier involvement of lighting designer which could result in more innovative designs; use of generic lamp efficacies, and luminaire

coefficients of utilization, in calculations procedures encourages

selecting sources and luminaires of higher quality for installation,

which should encourage research and innov^:ym by manufacture^^.

Design will result in a reduction in lamps and luminaires ; slightly higher design costs ; mor/e jjivolved installation with some reduction in total construction cost ; long term benefits to owner

and user; and will require careful scrutiny by enforcement agency.

Procedure GSA: budget can easily be prepared without involvement

of lighting designer; no incentive offered for innovation in

manufacture or design; author has no information on cost implication

84
but estimates it would average out to be same as for EMS-1, easy to

enforce

.

Procedure S: budget can be prepared without involvement of

lighting designer; no incentive offered for innovation in manufacture

or design; author has no information on cost implications; easy to

enforce

.

SUMMATION AND CONCLUSION

Effectiveness

The EMS-1 procedure has the greatest potential for energy

conservation, but the effectiveness is dependent on how the designer

administers, and the regulator audits, the budget calculations. The

GSA procedure rewards efficient space design as the budget is based on net rentable space and power for lighting other spaces must be gleaned

from this power maximum. Both the GSA and S procedures are prescriptive and offer little incentive or challenge to reduce power

load below specified amount. (See Appendix 3.)

Propriety

Herein lies the significant difference in the procedures. The

EMS-1 power budget is derived from criteria of high propriety for a specific space, whereas the GSA and S procedures have pre established

power limit that does not relate to a specific space or space

utilization. All three procedures rely on the designer to achieve

proper lighting.

Applicability

The EMS-1 procedure will be difficult to implement at the plan

inspection stage with consistency and fairness unless proper training

is achieved. The GSA and S procedure can be easily implemented at the

plan inspection stage. All three procedures are equally easy to check

for construction compliance.

Design costs will increase slightly where the EMS-1 procedure is

chosen; other implications are dependent on how the building community

responds. The regulator will serve a critical roll if a designer

chooses to circumvent the intent of the EMS-1 procedure.

A word of caution on reducing lighting levels--allowing for the

impact on heating and cooling systems and using a rate of $.03 per kWh

--a fifty footcandle increase in lighting level can be achieved for

less than $.13 per sq. ft. per year. Assuming a 200 sq. ft. office,

this amounts to $26.00 or .13 percent of the wage of a $20,000 per

year employee. A productivity test conducted by the Illuminating

Engineering Research Institute showed a 3 percent rise in productivity

(higher rise recorded under many circumstances) when lighting was

85
increased from 50 to 100 footcandles. This indicates that if the

additional 50 footcandle of lighting were^ Jieeded 4 percent of the

time, it would be economically justified.

The EMS-1 procedure offers a challenge that the building

community should not only accept but should support with vigor. It i the only procedure available that approaches the problem in a professional manner enabling the competent energy conscious members o the building community to excell. Granted there will be a period of

adoption but the instrument is designed to achieve the right results

for the right reasons.

86
REFERENCES

1. P.W. Cooke and R. M. Eisenhard, Building Energy Conservation

Programs--A Preliminary Examination of Regulatory Activities

at the State Level , NBSIR 77-1259. National Bureau of Standards

(available from National Technical Information Service,

Springfield, Virginia 22151, 124 pages, $5.50),

2. B. M. Hannan, R. G. Stein, B. Segal, D. Serber, and C. Stein,

Energy Use For Building Construction , CAC Document No. 228,

Center for Advanced Computations, University of Illinois, Urbana,

Illinois, 61801. February 1977, 185 pages.

3. Ibid . , p. 89.

4. Ibid . , p. 91.

5. Illuminating Engineering Society, lES Lighting Handbook Fifth

Edition (available from lES , 345 East 47th St., New York, N. Y. 10017, $37.50), p. 9-88.

6 . ASHRAE , Energy Conservation in New Building Design Standard 90-75

(available from ASHRAE Circulation Sales Department, 345 East

47th St., New York, N. Y. 10017, $10.35).

7. Illuminating Engineering Society, lES Recommended Lighting Power

Budget Determination Procedure--EMS-l . (Available from lES, see 5,

$6.50.)

8. General Services Administration, Energy Conservation Guidelines

for Existing Office Buildings , February 1977 (available from GSA

Business Service Center, 7th and D Streets, S.W. , Washington,

D.C. 20407, $2.00).

9. Federal Energy Administration, An Impact Assessment of ASHRAE

Standard 90-75 Conservation Paper Number 43B , p. 26.

10. Ibid . , p. 154.

11. Ibid . , p. 159.

12. Ibid. , p. 7.

13. Ibid.

14. R. T. Doresy, Cost Benefit Analysis Applied to Lighting in the

Energy Equation , Lighting Design and Application, Vol. 5, No. 7 (July 1975), pp. 36, 38.

87
BIBLIOGRAPHY

Federal Energy Administration. Lighting and Thermal Operations . (Available from Superintendent of Documents, U. S. Government

Printing Office, Washington, D. C. 20402, $2.30.)

lES . An Interim Report Relating the Lighting Design Procedure to

Effective Energy Utilization EMS-3 . (Available from lES, $4.50-)

lES . Example of the Use of the lES Recommended Lighting Power Budget

Determination Procedure EMS-3 . (Available from lES, $6.50.)

National Electrical Contractors Association, Total Energy Management

In Existing Buildings--A Model Standard . (Available from NECA,

7315 Wisconsin Ave., Washington, D. C. 20014.)

National Institute for Occupational Safety and Health.

The Occupational Safety and Health Effects Associated with

Reduced Levels of Illumination, Proceedings of a Symposium

July 11, 12, 1974 . HEW Publication No. (NIOSH) 75-142.

88
APPENDIX 1

EMS-1 PROCEDURE

The lighting power budget, as determined by the EMS-1 procedure,

is the sum of the lighting power requirements computed for all

interior spaces and exterior areas in accordance with the following:

Power limit determination: The power requirements for a specific

space is computed by summing the watts allowable for task lighting,

general lighting, non-critical lighting, and special lighting.

Special lighting is included at actual watts but the others are calculated by the following equation:

A (area) x FC (footcandle)

W (watts) = LE (lamp efficacy) X CU (luminaire coefficient utilization)

X LLF (light loss factor)

Area: An allowance of 50 square feet is made for each work

station where a task is performed, the remaining area in the space, up

to an amount equal to the total task area is classified as general

lighting and any area still remaining is considered non-critical.

Footcandle: For the most critical task performed at each work

station an illumination level as recommended by the lES Handbook will

be allowed. The general lighting shall be one-third of the weighted

task illumination but no less than 20 footcandles. The non-critical

lighting shall be one-third of the general lighting but no less than

10 footcandles.

Lamp Efficacy: The value for lamp efficacy shall be chosen from

the following: 55 lumen per watt where moderated color rendition is

appropriate; 40 Im/W for good color; and 25 Im/W if high color

rendition is appropriate.

Coefficient of Utilization: The coefficient of utilization (CU)

is in effect the ratio of the lumen received on the workplane to the

total lamp lumen. It is affected by three variables: First, the

geometry of the room as expressed by the room cavity ratio (RCR)

;

second, the reflectances of the room's ceiling, wall and floor—which In

the budget procedure are given as 80%, 50%, and 20%; and third, the

efficiency of the luminaire.

L + W

The RCR is calculated by the equation: RCR = 5 hrc

y

where

hrc is the distance from the luminaire to the workplane, ana L and W

are the length and width of the room.

89
The luminaire selected for use in the computations shall be of one of the generic types as listed in the Illuminating Engineering

Society Lighting Handbook, 5th Edition, but the luminaire must pass

one of the following tests.

Under the specified condition of reflectances of 80% (ceiling)

50% (walls), 20% (floor), and for a room cavity ratio of one, the

coefficient of utilization must be at least .55 for a space where the

illumination is specified as equivalent sphere illumination (ESI) and

the visual comfort probability (VCP) is required to be high; .63 for a space where VCP is a requirement but ESI is not; or .70 where neither

VCP or ESI are design requirements (see example 1).

Once the luminare has passed the test, the CU value shall be

extrapolated for the RCR of the specific room for which the power

limit is being computed.

Light Loss Factor (LLF) : A measure of the depreciation of the

illumination over time, given as a set value of .70 for the budget

procedure

Example: The following computations for two office areas are given to illustrate the application of the procedure.

Budget parameters:

Reflectances of 80, 50, 20, and a light loss factor of .70.

Coefficient of Utilization from accompanying table.

Room A: a small office L=15, W=10, hrc=6.5.

Room B: an open office L=100, W=100, hrc=10.

Task area is 50% of total area.

Room A

Room B

Room A

Room B

Room A

RCR=5

RCR=5

6.5 X

10 X

25

1500

200

10000

CU= .41 for an RCR=5

= 5.4

= 1

4.

CU= .65 for an RCR=1

Task area 75 sq. ft. recommended task

illumination 50 fc, moderate color

For tasks W=

75 X 50

For general W=

55 X .41 X

75 X 20

55 X .41 X .7

238 watts

95 watts

Typkal LiNiiinalra

Fluorescent unit with flat priS' malic lens. 4 lamp 2' wide

multiply by 1.10 for 2 lamp

Typkol DbtrJlHillMt and f9t C«nl lamp Lwmani

MoM.

Col.

MoslmMli S/MH

1.4/1 2

(0

30 cr

i

.71 .65

.69 .S3

.48

.43 .38 .36

.32

.2g .as

(Budget) Power limit for room 333 watts

2.22 watts per square foot.

90
Room B Task area 5000 sq. ft recommended task illumination 50 fc,

moderate color

For tasks W=

5000 x 50 ^ ^^^^ ^^^^^

55 X .65 X .70

n 1 17- 5000 X 20 _ General W= r-r — = 3996 watts

55 X .65 X .70

(Budget) power limit for space 13986 watts

1.4 watts per square foot

91
APPENDIX 2

GSA PROCEDURE

Although the GSA power limit is a prescriptive 2.3 watts per

square foot, it does make design recommendations. Of special interest

is the recommended method for determining illumination levels of office tasks.

The method is based on the visual difficulty rating listed below.

Visual Difficulty Rating (R) of Tasks

Visual

Task Description Difficulty

Rating (R)

1. Large Black Object on White Background 1

2. Book or Magazine, Printed Matter, 8-Point and Larger 2

3. Typed Original 2

4. Ink Writing (Script) 3

5 . Newspaper Text 4

6. Shorthand Notes, Ink 4

7. Handwriting (Script) in No. 2 Pencil 5

8. Shorthand Notes, No. 3 Pencil 6

9. "Washed-Out" Copy from Copying Machine 7

10. Bookkeeping 8

11. Drafting 8

12. Telephone Directory 12

13. Typed Carbon, Fifth Copy 15

The values from this table are multiplied by the hours of performance

per day, and if the worker is over 50 years of age, by a factor of

1.5. This visual difficulty factor is used to enter the following

table to determine the necessary illumination.

92
Recommended Illumination Levels for Office Tasks

Task or Area

Visual

Difficulty

(VDF)

Design

Level

(FC)

Average Level

Range

(FC)

Service of Public Areas 15 12-18

Circulation Areas within Office

Space, but not at Work Stations 30 24-36

Normal Office Work, Reading,

Writing, etc. 1-39 50 40-60

Office Work, Prolonged, Visually

uimcu±L or L.riLica± in iNature M-u- jy 7 c ou y

u

Office Work, Prolonged, Visually

Difficult and Critical in Nature 60 & Up 100 80-120

Example:

Task Hours Visual Difficulty Rat ing Visual Difficulty Factor

Read Newspaper 1 4 4

Typed Originals 2 2 4

Ink Writing 1 3 J

Washout Copy 2 7

Shorthand Notes 2 6 12

Total 8 37

For worker under 50 50fc

For worker over 50 75fc

93
APPENDIX 3

PROCEDURES COMPARISON

watts per square foot (EMS-1, task area 50% of total, moderate color)

Procedure Room Task Illumination

50 fc 75 fc 100 fc

EMS-1 A 2.22 3.16 4.2

B 1.4 2.0 2.7

GSA A or B 2.3 2.3 2.3

S A or B 3 3 3

Room A 15 X 10 X 9 small office

Room B 100 X 100 x 12.5 open office

94
THE NEED FOR A MORE EXPLICIT DEFINITION IN BUILDING REGULATIONS

OF THE INTERNAL THERMAL ENVIRONMENT IN BUILDINGS*

by

1 2 2 Dean R. Heerwagen , Ashley F. Emery Charles J. Kippenhan , and

Gordon B. Varey

A survey of several widely-accepted or newly-proposed building

codes or standards has been conducted to determine (1) what guidelines

for establishing occupant thermal comfort currently exist, and (2)

whether these guidelines may inhibit the achievement of energy

conservation in building operation. This review has shown that the

present requirements pertaining to thermal comfort afford non-optimal

conditions, from the points of view of both the provision of thermal

comfort and the achievement of energy conservation. In this essay,

the authors have cited results from three groups of researchers who

have provided definitive work on human thermal comfort. It is

suggested that such results be used in writing future building

regulations and that energy conservation will result from their

inclusions. Additionally, the authors have also suggested that future

regulations require the use of several innovative devices or strategies (for building operation or control) and these are discussed.

A thermal simulation computer program UWENSOL is described and

its application is displayed as a means of accurately predicting both

heating and cooling loads and thermal conditions within buildings

during their design.

Keywords: Building performance simulation' building regulations;

computer applications; energy conservation; thermal

comfort; thermal performance of buildings.

Acting Associate Professor of Architecture and Member of the

Building Environment Studies/Teaching and Research (BES/TR) Group,

Institute for Environmental Studies, University of Washington,

Seattle, Washington.

2Professor of Mechanical Engineering and Member of the BES/TR

Group in the lES, University of Washington, Seattle, Washington.

3Professor of Architecture and Principal Investigator for the

BES/TR Group in the lES, University of Washington, Seattle,

Washington.

*This work is a partial result of research being carried out with

a grant from the Department of Social and Health Services, Washington

State Government, Contract #8072 FGF 10432.

95
INTRODUCTION

In the Institute for Environmental Studies at the University of

Washington, an interdisciplinary team of architects, engineers, and

atmospheric scientists has been organized. This group is currently

seeking to develop design guidelines for buildings, which will result

in the conservation of energy during the life of the buildings.

Throughout this study, we have recognized that energy is used in

buildings to provide a comfortable environment for occupants to live

and work. The provision of comfort has been taken as a fundamental

issue; to offer conditions which of themselves produce appreciable

occupant discomfort will likley reduce the ability of the building

occupant to perform desired or required activities, whether in a home

or work situation. Thus, our goal for this research is to identify

means by which energy consumption can be reduced without adversely

affecting the occupant's well-being.

In this essay we will describe our considerations and preliminary

conclusions about four issues central to this goal: (1) the

identification of a comfort envelope that is as broadly-defined as to

be still acceptable by the building occupants; (2) the consideration

of practices which can be used to overcome potentially uncomfortable

environmental conditions; (3) the suggestion of innovative devices and

strategies that can improve current methods for attaining comfort; and

(4) the description and use of a computer tool by which building

performance can be simulated accurately during the designing of the

building (to permit determination of whether comfort conditions would

exist). We will document these considerations and conclusions,

initially, by reference to the various applicable building regulations

and standards on the subject of thermal comfort and to definitive

research on conditions for achieving occupant thermal comfort and,

subsequently, by describing a series of calculations performed through

the use of our thermal simulation computer program.

A REVIEW OF THERMAL COMFORT GUIDELINES PROVIDED BY EXISTING

(AND PROPOSED) BUILDING CODES AND PROFESSIONAL STANDARDS

When our research group began to evaluate the series of building

concepts that we anticipated could provide substantial conservation

opportunities, we carefully reviewed the appropriate building codes

and industry standards for required thermal comfort provisions in

buildings. Guidelines were sought about the four primary variables

that determine the character of the internal building environment:

(1) ambient air temperature, (2) mean radiant temperature,

(3) relative air velocity, and (4) relative humidity. We found that the

codes and standards which govern how buildings are to be constructed

are largely imprecise and that generally little recognition has been

given to insuring occupant thermal comfort. In this section, we will

summarize the results of our review of the several codes and

standards, and in the next section we shall cite and describe research

conducted by numbers of experimenters, which offer rigorously-based

guidelines for insuring occupant thermal comfort.

96
To digress momentarily on the function of building regulations:

building regulations -- whether promulgated as codes or as standards -- have been used in the United States to guarantee the

well-being and safety of the building occupant. Such regulations

protect the occupant against faulty design and construction by

providing "...minimum standards ^to safeguard life or limb, health,

property, and public welfare..." of the occupants and those who live

or work around the regulated buildings. But, rather than simply

setting "minimum standards," it can be argued that future regulations

should include statements which will cause the achievement of markedly

improved building thermal performances. We do not wish to require

absolute efficiencies (e.g., such as by prescribing minimum U-values

for the building envelope); rather, we would wish that regulations

subsequent to existing codes and standards be upgraded to reflect

improved knowledge and professional competencies. To illustrate this,

argument, we note that the already well known ASHRAE Standard 90-75

has established guidelines for buildings which, when issued, exceeded

all then-current codes in many respects. But, as we will argue below,

if the indoor temperatures specified in this Standard had been altered

to those comfort conditions that were known from research that had

been conducted and verified some years before the issuance of the

Standard, then appreciably better building performance would be

achievable

.

For architects and engineers who are designing buildings to be

constructed in the State of Washington, the primary set of regulations

that must be satisfied for all buildings occupied by human beings is

the Uniform Buildinfe.Code , issued by the International Conference of

Building Officials . This Code directly stipulates a heating

requirement only for residential units (i.e., single and multiple-unit

private housing and all public units such as hotels and motels). The

requirement reads that "every dwelling unit and guest room shall be

provided with heating facilities capable of maintaining a room temperature of 70^F at a point three feet above the floor in all

ha|)itable rooms." Ventilation rates are given for all occupied

building types, but permissible velocities are noted only for air

movement directly from the supply registers. For buildings used for

non-residential occupancies, air temperatures are not specified. In

the index to this Code, the reader is referred to the Uniform

Mechanical Code which is also piiblished by the International

Conference of Building Officials . The Mechanical Code , however,

does not list requirements for occupant thermal comfort and instead is

concerned primarily with the construction and operation of the various

heating, ventilating, and air conditioning equipment commonly used in

buildings

.

For further information regarding minimum or recommended internal

building conditions (i.e., those including ambient air and mean

radiant temperatures, relative humidity, and relative air velocity),

Section 102, Uniform Building Code , 1976 Edition. Page 23.

Section 1311, Uniform Building Code , 1976 Edition. Page 91.

97
the building designer might consult the three ASHRAE Standards which

address themselves, directly or otherwise, to the internal building

environment: (1) Standard 55-74, "Thermal Environmental Conditions

for Human Occupancy;" (2) Standard 62-73, "Standards for Natural

and Mechanical Ventilation;"^^'' and (3) Standard 90-75, "Energy

Conservation in New Building Design." (1)

Of these three documents, the first Standard (55-74) is by far

the most comprehensive of the three in providing direction for

establishing occupant thermal comfort. This Standard defines a "comfort envelope" in which it is said that at least 80% of the

normally-clothed North American men and women will be thermally

comfortable while pursuing sedentary or similarly light work

activities indoors. This comfort envelope (Figure 1) is based on two

variables: (1) adjusted dry-bulb temperature and (2) water vapor

pressure. The specific statements in the Standard which describe

these variables and which define the comfort evelope are given below:

(Section 3.1) When the dry-bulb temperature equals the mean radiant

temperature (MRT) , the dry-bulb temperature equals the

adjusted dry-bulb temperature (ADBT) , as defined by the

following equation:

ADBT = 1/2 (DBT + MRT)

When the mean radiant temperature is different from the

dry-bulb temperature, a compensation is made as noted

in the following item below. The comfort envelope is

defined as a quadrangle with the following corner

coordinates: ADBT = 71.5 and 77.6°F at 14 mm Hg vapor

pressure and ADBT = 72.6 and 79. 7^ at 5 mm Hg vapor

pressure

(Section 3.3) When the mean radiant temperature in the occupied zone differs from the dry-bulb temperature, the dry-bulb

temperature shall be reduced by one degree (F) for each

degree mean radiant temperature elevation above the air

temperature and vice versa.

(Section 3.2) The water vapor pressure in the occupied zone shall be

at or between 5.0 and 14.0 mm Hg. These conditions

correspond approximately to 20 and 65% relative

humidity.

(Section 3.4) The air velocity in the occupied zone shall be 70

feet/minute or less at any time.

Of the other two ASHRAE Standards responsible for defining

internal building conditions, the Standard 90-75 closely follows the

contents of Standard 55-74 in defining permissible dry-bulb

Section 2.1, ASHRAE Standard 55-74, "Thermal Environmental

Conditions for Occupancy." Page 3.

98
99
temperature and relative humidity. This Standard (90-75) states that

all building and systems calculations shall be based on interior

dry-bulb temperature of 72°F for the winter and 78°F for the summer. Relative humidity levels are limited to a maximum of 30% where

humidif ication is required during winter mechanical equipment

operation. Summer humidity levels are fixed according to those

boundaries set by the comfort envelope defined in Standard 55-74. No

specific requirements are noted for the other two environmental

variables (i.e., mean radiant temperature and relative air velocity).

The third Standard (62-73) provides minimum and recommended guidelines

for natural and mechanical ventilation. Its primary function is to

furnish suggested ventilation rates and permissible contaminant

contents in the supply air. There is no specific mention of

recommended internal thermal design conditions.

Lastly, the foresighted Washington State building designer might

consider two additional sources of regulative guidelines: (1) the

proposed "Energy Conservation Standards for Non-regidential Buildings"

currently under review by the State of California ; and (2) the preliminary draft of the .i^'Model Code for Energy Conservation in New

Building Construction' , which is being developed jointly by (a)

Building Officials and Code Administrators International, Inc. (BOCA),

(b) International Conference of Building Officials (ICBO) , and (c)

Southern Building Code Congress International, Inc. (SBCC)

Both of these model codes, for instance, are being reviewed by

the City of Seattle Energy Office as bases for the inclusion of energy

standards in the City building code (which is, in turn, based on the

Uniform Building Code ) . Each of these model codes has been written

using the ASHRAE Stmdard 90-75 as a basis, and each has sought to

alter the technical content of the parent Standard as little as possible. The California proposal differs from the ASHRAE Standard

only where 70°F is suggested as an indoor design temperature. In an apparent conceptual inconsistency, it is suggested that the HVAC

equipment be designed to recognize the comfort envelope established by

ASHRAE Standard 55-74. The model code being developed by the three

primary national code-writing organizations specifically states its

reliance on the Standard 55-74 for a definition of a thermal comfort

envelope

To summarize our findings from this review of applicable building

codes and standards, the legally-binding building regulation for

designers in the Pacific Northwest is the Uniform Building Code . As we have noted, its tenet for establishing occupant thermal comfort

applies only to residential buildings and then the regulation requires

that heating be provided that is capable of maintaining an air

temperature of 70°F. Of the three standards and the two proposed code

amendments, all but the ASHRAE Standard 62-73 cite the comfort

envelope initially described in ASHRAE Standard 55-74 as the basis for

defining thermal comfort. With the likely passage of the proposed

model code that has been jointly developed by the three most

widely-accepted regulating bodies, this comfort envelope will become

the new definition for comfort conditions.

100
LESSONS FROM RECENT RESEARCH ON HUMAN THERMAL COMFORT

It is our contention that the comfort envelope defined in the

ASHRAE Standard 55-74 is too conservative. The various research

findings described below substantiate our belief that a larger

envelope can, in fact, be used to define conditions with which the

building occupant will be comfortable. Results in Section IV will

demonstrate that the definition of such a larger comfort zone will

offer marked energy conservation opportunities.

First, let us point out that the temperature criteria. ^or thermal

comfort rose steadily between 1900 and 1960. When Nevins in 1961

surveyed temperature requirements developed over that 60-year period,

he found that a temperature range of 65 to 70°F (DBT) was acceptable

in 1900, but that by 1960, the temperature range that was recommended

for human comfort was 75 to 78°F (DBT) -- both ranges being given for

40% relative humidity. The reasons for this steady increase are probably several: the reduction in the weight of clothing (and thus,

to a marked extent, in its ability to insulate), the ease with which

heating could be achieved (with the ready availability of fossil

fuels), changes in living habits, and changes in the way buildings

have been built. Whatever the precise reason, it is important to

recognize that a person's feeling of comfort is directly related to

the individual's ability to respond to the various environmental

conditions that impinge on his/her physiological state. Besides the

primary environmental factors of the ambient air and mean radiant

temperatures, the relative humidity of the air, and the relative air

velocity moving about the person, two additional personal variables

also have a direct and marked effect on the comfort level of the

building occupant: (1) the activity level of the occupant (or, the

metabolic rate of internal heat production) , and (2) the thermal^

resistance of the occupant's clothing (as described in terms of clo ).

Nearly all of the recent research on human comfort has recognized

these six factors as those which determine the nature of the

individual's physiological response to the building environment.

During the last fifty years, there has been a succession of

indices, equations, and envelopes or zones developed -- numbering at

least a dozen -- for predicting thermal comfort. Th^e have been

ribed in the ^literature by such authors as Newburg , Hill et al

, and Givoni . Beginning with Houghton and Yaglou's work [for

example, 12] in the 1920 's and continuing through to the early 1960's,

most of the efforts spent on characterizing human comfort were organized around the development of a series of thermal indices, which

could be used to predict physiological responses to varying

A clo is "the amount of insulation necessary to maintain comfort

and a mean skin temperature of 90°F in a room at 70°F with air

movement not over 10 feet/minute, humidity not over 50%, with a metabolism of 50 Calories/square meter/hour." From Newburgh, L. H. (editor) Physiology of Heat Regulation and the Science of Clothing . New York: Hafner Publishing Company, 1968. Page 442. Numerically,

1 clo = 0 . 18°C/cal-sq. meter-hour.

101
environmental conditions. Some of these indices were rationally

derived from research, whereas others result from empiricism. As

Givoni has demonstrated by comparing the several indices, they differ

most frequently in at least four significant respects: (1) the

specific environmental and personal factors and physiological

responses that are addressed, (2) the manners in which these factors

and responses are weighted for relative importance and how or whether

the factors and responses are interdependent, (3) the range of

environmental conditions in which these indices are applicable, and

(4) the forms in which the various indices are expressed. Generally,

the results of using these indices were less satisfactory than might

be wished and reliance upon them as descriptors or predictors of

comfort conditions has declined. Instead, during the last fifteen

years, the development of such indices has given way to the

establishment of thermal comfort envelopes (such as the one on which

the ASHRAE Standard 55-74 is based). Three major research efforts

have been undertaken during this period and specific recommendations

about comfort conditions have been advanced from each. The initial

work was begun by Nevins and his colleagues at Kansas State University

in the 1960's. Through collaboration with Nevins and his associates

and from much additional independent work, two other groups have also

made important contributions to this study area. Specifically, one group has been led by Gagge at the Pierce Foundation Laboratory in New

Haven, and the other has been directed by Fanger at the Technical

University of Denmark. In the following paragraphs, we will briefly

describe these important researches and summarize their results.

(13) The work by Nevins and his colleagues was begun in 1963.

Initially, they sought to identify a comfort zone based on dry-bulb

temperature and relative humidity scales by noting how test subjects

evaluated specific thermal environmental conditions when the ambient

air temperature and relative humidity were varied. The subjects were asked to describe the various environmental conditions in terms of a seven-point rating scale, ranging from "cold" to "hot" with

"comfortable" at the median point. As such, the evaluations by the

test subjects were based more precisely on their thermal sensation

capabilities than on the more general issue^.of thermal comfort.

Subsequent research, as reported by Rohles , then led to the

development of a "Modal Comfort Envelope."

In the research conducted at Kansas State University, 720

subjects (equally divided by sex) were tested in the experiments that

led to the first paper noted above, and a total of 1600 -- the first

720 subjects plus an additional 880 -- were examined and later

reported about in the second paper. Using the data that were collected from the first set of observations, a "Baseline Comfort

Chart" was drawn (see Figure 2 for a reproduction of this Chart).

Following the additional testing, the Modal Comfort Chart was derived

(see Figure 3). The first Chart contains three lines -- on what is

See Givoni, B. Man, Climate and Architecture , Second Edition.

London: Applied Science Publishers, Ltd., 1976. Chapter 5,

pp. 75-102.

102
66 70 74 78 82 86

DRY BULB TEMPERATURE, T

FIGURE 2: The Baseline Comfort Chart

(from Nevins et al [13], page 289)

103
DRY BULB TEMPERATURE, T

FIGURE 3: The Modal Comfort Envelope

(from Rohles [14])

104
essentially a modified Psychrometric Chart -- noting, respectively,

conditions of being "slightly cool," "comfortable," and "slightly

warm." The Modal Comfort Chart is drawn with an envelope overlaid on these three lines, with the envelope signifying the zone in which the

test subjects were comfortable.

The second major comfort work group is the one led by Fanger at

the Technical University jot^Denmark. This work has been summarized in

his book Thermal Comfort . He began his work by seeking to relate

the several environmental and personal factors that influence the

maintenance of comfort with the several mechanisms by which heat is

lost or gained by the human body. From the resultant relationships

describing these heat exchange mechanisms, Fanger has been able to

derive a comphrehensive equation which allows the calculation of

whether an individual will be comfortable when exposed to a specific

set of environmental conditions and for particular metabolic

(activity) rates and clothing insulation levels. Following the

derivation of this Comfort Equation, Fanger then compiled a group of

nomographs in which combinations of the several environmental and

personal factors are compared; these nomographs have thus been set

forth as "comfort diagrams." His intention was that such diagrams

could be used in general practice without the iterative solution of

the extended and quite complex Comfort Equation.

Following his derivation of the Comfort Envelope, Fanger set

about relating the use of this Equation to the evaluation of specific

room climates. Using a rating scale similar to the one established by

Nevins and his colleagues, he developed the concejxt of a "Predicted

Mean,yote." From data supplied by Nevins et al and McNall et

al for sedentary and active subjects, respectively, Fanger found

that the predicted mean vote (PMV) was indeed a function of the six

environmental and personal factors to which the test subjects were

exposed. Thus, an equation in which the PMV could be predixCted

evolved and has been summarized in his book Thermal Comfort . This

equation, relating the PMV with the six variables and, necessarily,

with the several heat exchange mechanisms, permits one to determine

the likelihood that an individual will feel comfortable or not when

exposed to a given set of conditions (for the results of a set of

sample calculations for an individual wearing clothing rated at 0.60

clo, see Figure 4). The other valuable concept developed by Fanger is

the "Predicted Percentage of Dissatisfied" people that will be

uncomfortable when they experience some set of environmental and

personal conditions. The "predicted percentage of dissatisfied" (PPD)

is directly related to the PMV for any set of conditions and an equation describing the relationship has been developed by Hill et

In general, the great value of Fanger' s work is that it allows

calculation, by digital computer, of whether the occupants of some space will be comfortable when exposed to any set of environmental

conditions while clothed in a particular fashion and pursuing a specific activity. As such, this calculation device can be used as a design aid ^to. evaluate any building space prior to its construction.

Hill et al have pointed out that, if there is a difficulty with

Fanger 's PMV and PPD ratings, it is that the predicted lines of

105
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106
relatively small and larger discomfort do not quite match those

results found by Nevins , Rohles, and their colleagues who established

their comfort guidelines from observations of a large sample of test

subjects. Whereas the predicted ratings determined from the Fanger

equations and the observed ratings from the test subjects gathered by

Nevins, Rohles and their associates do differ in the zones of greater

discomfort, the results of the two researches agree closely in the area of what is indeed comfortable.

The third major research effort towards establishing a definitive

description of a thermal comfort zone is the work that has been in

progress for the last decade at the John B. Pierce Foundation

Laboratory in New Haven. Much of this group's primary work surrounds

the development and application of a new version of the old thermal

of the human being's various heat exchange mecahnisms (it could be

argued that the ET" scale may be more accurate than the Comfort

Equation for conditions just out of the immediate comfort range

because the ET" scale includes the exchange effects due to

vasoregulation) . In Figure 5, lines of the New Effective Temperature

scale have been drawn on a Psychrometric Chart. An interpretation

noting the significances of the various ET* ratings is presented in

Table 1.

The ET* scale is essentially an analytic device that can be used

to ascertain the likelihood of thermal comfort being achieved when the

various environmental conditions are known and the clothing worn by

the particular occupants and their specific activities (and, thus,

their metabolic rates of heat production) have been established. As

with Fanger' s Comfort Equation, the New Effective Temperature scale

recognizes the essential importance of the insulative value of

clothing and of the activity rate as means of offsetting environmental

conditions when one or more of these latter variables proves

insufficient for meeting thermal comfort needs.

For our purposes here, the development of this New Effective

Temperature scale is perhaps of less direct importance -- except as a means of verifying the results of a later study that is particularly

noteworthy -- than this later study. In conjunction with their work

on thi^gjiew comfort scale and in assocation with Nevins, a recent

study was performed for the Federal Energy Administration which

bears directly on the subject of this paper. In 1974, the FEA

established building operating temperature guidelines for winter and summer conditions which differed from those presented in the ASHRAE

Standard 55-74. The specific temperatures set by the FEA were 68-70°F

for winter operation and 78-80°F for summer operation (with a proposed

80-82''F to be examined for later promulgation, pending further study).

For the siuraner, humidity control was also to be avoided in the

operation of the FEA buildings. The Pierce Foundation Laboratory team

was asked to determine if these new standards were reasonable and

what observations these researchers might make about the acceptability

of these guidelines. The results of this investigation have been

summarized in a report prepared by Gagge and Nevins

107
108 I

I

I
HUMAN RESPONSE TO THERMAL ENVIRONMENT

(For sedentary, clothed subjects)

NEW T~.. SCALE eff

Op

110^

100

90

80

70

CO

50

40 _

(at 50% rh)

SENSATION

Temperature Comfort

Limited tolerance

Very hot

Hot

Uncomfortable

Warm

Slightly

Warm

Neutral

Slightly

Cool

Cool

Cold

Very cold

Slightly

Uncomfortable

Comfortable

Slightly

uncomfortable

Uncomfortable

PHYSIOLOGY

Body heating

Failure of regulation

Increasing stress caused

by sweating and blood flow

Normal regulation by sweating

and vascular change

Regulation by

vascular change

Increasing dry heat loss;

Urge for more clothi.ng or exercise (behavioral regulation)

Vasoconstriction in hands

and feet; shivering

TABLE 1: A listing of responses of sedentary, clothed subjects to environmental conditions that are described by the New

Effective Temperature (ET*) Scale (From Hardy [18]).

109
Whereas the thermal conditions set forth by the ASHRAE Standard

55-74 were re-validated as optimal for comfort, the authors noted

that -- using the acceptability criterion (i.e., that 80% of those who

are subjected to particular set of thermal conditions must be

comfortable) -- variations from the ASHRAE Standard were acceptable.

First, an upper limit on the temperature was placed at 78-80°F with

relative humidities up to 70% with the proviso that lighter clothing

be worn (ensembles rated at 0.4 clo or less). An ever higher

temperature range, specifically 80-82°F, can be made acceptable if one

or more of the following conditions were met: (1) the thermal

resistance of clothing ensembles is maintained at 0.3 to 0.4 clo; (2)

the relative air velocity is increased to the 50 to 100 fpm range,

and/or (3) the relative humidity is maintained at 40% or less.

Second, the temperature range of 68-70°F was found to be acceptable

(to 80% of more of the test subject) if the clothing ensembles worn by

the subjects had thermal resistance rating of 0.8 to 1.2 clo.

Additionally, temperature in the 66-68°F range were also found to be

acceptable if the temperature resistance of the clothing was maintained at the 0.8 to 1.2 clo level -- and it was evenly

distributed over the body -- and drafts around the neck and

extremities were avoided. The researchers observed that at both ends

of the temperature range there are sex-dependent differences in the

reaction to these extremes. Men appear to have a greater thermal

sensitivity at the upper region of the range, whereas women,

particularly those younger in age, seem to be more sensitive at the

lower range. Both sensitivities appear to be overcome by relying on

the aids noted above. Lastly, a primary conclusion was that "except

for the ill and those in hospitals, there appears to be no serious

health hazard for properly clothed individuals when exposed to

temperatures in the range of 68 to 80°F."

To sununarize the researches noted in this section, there is

considerable evidence to support that: (1) future building

regulations should be based on a temperature range of 68 to 80°F (or

possibly even 66 to 82°F) ; (2) such regulations should also describe

required variable ranges for the relative humidity and the relative

air velocity permitted in occupied space interiors (if not for the mean radiant temperature also) , and (3) the thermal comfort guidelines

set forth in the ASHRAE Standard 55-74 are too conservative. It

should be noted that more research has been done examining the results

of thermal comfort conditions at the upper end of the temperature

range listed above. But the recent work by Gagge, Nevins , and their

colleagues at the Pierce Foundation Laboratory has established

evidence for means of providing comfort at the lower end of the range

as well. It is extremely important to remember that the achievement

of thermal comfort is dependent on the insulative value of the

occupant's clothing and the form of activity being pursued by the

occupant, as well as on the four environmental factors of ambient air

and mean radiant temperatures, relative humidity, and relative air

velocity. We would in no manner wish to see future building

Gagge, A. P. and Nevins, R. G. "Effects of Energy Conservation

Guidelines on Comfort, Acceptability, and Health " [see 19]. Page 5.

110
regulations cite particular types of dress as mandatory (even if it were legal). Rather our interest is in emphasizing that intelligent

choices of clothing by building occupants can establish comfort at the

lower and upper ends of the 68 to 80°F or 66 to 82°F ranges.

Lastly, two additional issues that recent researchers have not

addressed with sufficient intensity yet and which are of importance in

developing comprehensive building regulations are: (1) nearly all the

measurements of comfort have been done for subjects who were sedentary

(passive) or were doing light office work; further work is required on acceptable thermal comfort ranges for building occupants pursuing the

many more active tasks that frequently occur in buildings; and (2)

each of the three major research efforts has identified thermal

conditions which were described as "slightly warm" or "slightly cool"

for some set of conditions; a question could then arise about whether

exposure to such conditions has any effect on one's work or living

task performance, and if not, could the acceptable range not be pushed

out a little farther (say, between 65 and 85°F)?

III. A DISCUSSION CONCERNING APPLICATIONS OF INNOVATIVE

SPACE CONDITIONING DEVICES AND STRATEGIES

In most buildings, several means are present which affect the

degree of thermal comfort experienced by the building occupant. The

heating, ventilating, and air conditioning system is, of course,

largely responsible for conditioning the building either by adding or removing heat energy. But other sources of heat energy are or may

also be present and these influence the maintenance of thermal comfort

conditions: lighting fixtures, process equipment associated with the

use of the building, incident solar radiation, and the body heat from

the occupants themselves. Thus, the operation of the HVAC system in

maintaining occupant comfort is dependent upon inputs from these

sources and heat losses through the building envelope. How well or quickly the HVAC system responds to meeting the occupants' needs when

such inputs or losses exist necessarily determines the quality and

efficiency of the performance of the system. Noting this qualification about the character of the response of a HVAC system, we have

identified a number of devices and use strategies whose adoptions will

likely improve the operation of such systems, as well as aiding the

achievement of thermal comfort. We would, therefore, advocate

recognition of these innovations in future building regulations.

An Advocacy for the Development and Use of Improved Control Systems

for Heating, Ventilating, and Air Conditioning Equipment

In an effort to improve the performance of buildings, both by

insuring occupant thermal comfort and by conserving energy, we would

suggest that future building regulations contain clauses which

designate the devices by which mechanical systems in buildings are controlled. Here we will note four specific approaches that are commercially available or which will soon be available. Each of these

will lead to reduced energy consumption in buildings without

111
infringing on occupant thermal comfort. It is indeed possible that,

for at least two of these approaches (namely, the second and fourth

suggestions below) , the likelihood of providing comfort may be

improved

The first of these approaches concerns the use of a dead-band

thermostatic control on HVAC equipment, in place of the common

single- temperature thermostat. For many mechanical systems with

three- or four-pipe hot and chilled-water conditioning, a one-temperature thermostat controls the operation of the system. When

the air temperature exceeds the set temperature (usually by no more than 1/2°F) , cooling will begin. Alternately, when the air

temperature falls below the set temperature (again, by the 1/2°F

margin), heating of the air will occur. Clearly, such precise

temperature control is rarely needed. Instead what should be required

is the use of dead-band thermostatic control where heating or cooling

occurs only when the air temperature, for instance, falls below 68°F

or rises above 80°F, respectively. From the results of the comfort

studies discussed in Section II, it should be clear that any

single-temperature maintenance is unnecessary for establishing

occupant comfort.

A second innovation whose use we advocate would be the

application of true enthalpy-based control systems. We would suggest

that rather than relying on individual thermostatic and humidistatic

sensors separately measuring the building environment and determining

the operation of the various HVAC systems components, controls should

be employed where enthalpy of the air is the determining variable.

Microprocessing circuitry is available for similar control functions

in other industries and could be modified to meet this control need.

Such microprocessors would permit the determination of the air

enthalpy employing the continuous measurements of the temperature and

relative humidity. Thus, enthalpy would control the mechanical system

and the use of these controls would minimize reliance on a single

combination of one temperature and one humidity as bases for

establishing comfort. With a true enthalpy-based control device, the

operation of the conditioning equipment could occur in response to

varying temperatures and humidities as long as the enthalpy remained

within a prescribed range (e.g., between 25 and 30 Btu/pound of dry

air and temperature limits of 68 and 80°F)

Two other control devices that are presently in use but which

should be more widely employed are (1) time-clock operation of HVAC

equipment, and (2) the establishment of additional zones of control in

buildings (rather than relying on a small number of control zones).

The first of these two devices simply provides the system with a clock

that either shuts down or sets back the heating system when the

building occupants are not present or when the residents are asleep.

Time-clock controls can also be employed for cooling systems for

situations when the applicable buildings are not occupied (e.g.,

offices, schools, or laboratories). The other control method noted in

this paragraph is one where, instead of using a one- or two-zone

control system for large spaces or for a grouped series of smaller

spaces with variable needs, smaller zones with the appropriate

112
sensors, controls, and temperature management devices are established.

Thus, reduction of meeting extreme conditions universally throughout a building can be accomplished.

Frequently, the application of such devices as these will have

higher associated installation costs than would less dynamic controls.

But, just as frequently, if life-cycle cost analyses are performed

against the projected life of the building, it will be shown that

appreciable savings can be realized. Also, the use of devices such as these will likely provide more thermally comfortable buildings. An

additional trade-off that must be considered is the economic balance

between the control system components and the air-moving, heat

transfer equipment. If better controls diminish the need for heating

or cooling equipment by more effectively utilizing this latter

equipment, then more precise controls will be justified. Another more

subtle savings may also occur by permitting the operation of the

heating or cooling equipment closer to the design capacity through the

employment of better control systems. To be avoided is the situation

where large-capacity heating or cooling equipment is established to

compensate for a lesser quality control system.

Construction of Buildings Which Respond Slowly to Changes in

Environmental Conditions

A number of books and papers have recently been published in the

American building literature (for example, 20 and 21) calling for the

renewed construction of heavy or massive buildings in place of the now commonly-built lightweight, thin-envelope architecture. We would

support the renewal of such an architectural style because the use of

massive envelopes causes those buildings to respond more slowly to

changes in environmental conditions (e.g., external temperature

changes, intense solar irradiation, etc.). The use of massive

buildings necessarily provides better assurance of maintaining

occupant thermal comfort without the total reliance on HVAC systems.

On the other hand, lightweight buildings respond quickly to environmental changes, and to insure occupant comfort, more dynamic

mechanical systems are required. How quickly buildings themselves or their HVAC equipment should respond to gradual, or even dramatic,

changes in conditions has not been well-established. If a thermal

comfort range such as one of those discussed above is accepted, then

the building and its attendant HVAC system can respond more slowly

than if a single temperature is required for comfort. Alternately,

when a massive building is permitted to cool down by using a temperature setback or by shutting the system off and then applying a warm-up period when occupancy is about to be resumed, appreciable

energy can be saved in contrast to the situation where the building is

maintained at a constant temperature level throughout the same period.

We believe that too much emphasis has recently been placed on achieving short response times for buildings and that reliance on devices necessary to provide these quick responses is frequently

energy-wasteful. Rather, we would strongly support the alternate

construction and operation of massive buildings with mechanical

systems of smaller capacities as an optimal means of achieving

occupant thermal comfort.

113
An alternate situation that should be noted is the employment of

a limited-capacity system to overcome a potentially uncomfortable

condition. The practice of nocturnally cooling a building even with an HVAC system of limited capacity -- is beneficial because the

external air is a virtually infinite heat sink. Thus, a building can

be cooled down during the night and, if it has appreciable mass, its

time delay for reaching its maximum internal temperature will be

sufficient to minimize the need for refrigeration during a hot day.

But, if you attempt in the morning to heat up a building which has

cooled off overnight, with a system of limited capacity, the response

time for the building to warm up will be lengthened. Thus, the

response time for a building when it is exposed to moderate to large

changes in environmental conditions can be dependent on the capacity

of the HVAC system, as well as on the character of the building

envelope

Guidelines about the Operation of Buildings

A last noteworthy issue concerning the performances of buildings

is that many building owners have recently begun to complain that the

behaviors of their buildings are different than were predicted by the

various designers. Upon review of the records of the performance,

however, it is found that the reason for the discrepancy is due to the

fact that buildings are being operated differently than the designers

had intended. Either controls are overriden manually or the schedule

of use is different from the program data given the designer or a building is not well maintained or any number of other difficulties

arise and have not been adequately overcome. We do not wish to

regulate the operation of buildings, nor do we expect that it is

legally feasible (short of imposing fuel rationing). Rather, we want

to note that such difficulties do occur and that perhaps building

designers should attempt to anticipate them and to try to prevent

their happenings

114
IV. THE USE OF A THERMAL SIMULATION COMPUTER PROGRAM

FOR PREDICTING THE THERMAL BEHAVIOR OF BUILDINGS

Until recently, the designers of buildings had no means to

simulate accurately the thermal performance of their proposed design

schemes. Calculation methods did exist which permitted the

determination of the steady-state response of buildings to various

heat sources and sinks within and outside the buildings. But these

calculations did not reveal the time-dependent effects of the

resultant heat fluxes. Transient-state calculations could be

performed for the prediction of short-time responses, but these

methods -- requiring numerous iterations -- were exceedingly complex

and tedious. Now, however, with the beginning of the development of

computer programs which will simulate accurately the thermal

performance of a building, the designer is able to determine the

behavior of the building or its parts when either is exposed to

varying heat gain and loss conditions. Thus, the thermal performance

of a building can be predetermined and the results of these

simulations can be used as the basis for making design decisions which

can improve the energy consumption requirements during the subsequent

operation of the completed building. In addition to seeking to

improve the performance of the building, the use of a thermal

simulation computer program permits the designer to determine whether

thermal comfort conditions will be present when the building is

subjected to the several heat sources and sinks over time. Such a program can also calculate the amount of heating or cooling that will

be required for offsetting heat fluxes, whose effects could cause occupant discomfort if not overcome.

We are currently developing and using a digital computation

program, with which we are examining the thermal behavior of a number

of building conditions. Our development of this program (called

UWENSOL) has arisen from a research study in which we are seeking to

identify and evaluate various energy-conserving techniques for a series of buildings projected for subsequent construction. In July

1976, our research team commenced work on this study at the request of

the Washington State Legislature and the State Government's Department

of Social and Health Services. The administration of this Department

charged our team to: (1) choose two specific buildings within the

range of projects that were anticipated for construction starts, and

determine suitable energy-conserving guidelines for the future design

and construction of these buildings; (2) following the establishment

of such guidelines, serve as participants, with the architects and

engineers, in the design phase of these buildings; and (3) after

occupancy, test and evaluate the performance of the buildings to

determine how well the various means for conserving energy were

functioning.

The primary goals of the research team while participating in

this study, have been to improve the technique of energy-efficient

architectural design by the maximal use of passive means of energy

control, to pursue appropriate trade-off analyses to foster the

optimization of the use of such passive devices, and to integrate the

passive devices with traditional and innovative active mechanical

115
systems. Thus, our intentions are to reduce both peak and average

consumptions of energy. To conduct the systematic evaluation of these

devices, members of the stmiy team have developed the digital

computation program UWENSOL which permits precise characterization

of energy flows throughout buildings. This program is essentially a set of interconnected numerical algorithms, which in its entirety

provides a comprehensive thermal simulation of any building subjected

to common heat gain and loss sources.*

The implementation of the program UWENSOL requires three basic

sets of information: (1) a careful description of the building form,

including its geometry and the composition of the building envelope

(i.e., surface areas and an indication of the materials employed in

the envelope); (2) an hour-by-hour schedule of the occupant's presence

and their employment of various devices that cause the flow of energy

(e.g., lights, process equipment, primary and supplemental heating and

cooling systems, etc); and (3) a detailed hourly listing of weather

data (e.g., solar radiation and positioning, cloud cover presence, the

various temperatures, wind speed, and humidity, etc.) Once these data

sets are provided, it is possible to calculate -- over time and for

various rooms -- heating and cooling loads for equipment sizing, the room air temperature, the temperatures at the surfaces of each room,

the mean radiant temperatures in the room, and the humidity and

enthalphy of the room air.

The use of the program UWENSOL thus provides the research team

with a highly accurate means of simulating building thermal

performance in response to changing (or transient) internal and

environmental conditions. In the remainder of this Section, we will

describe a series of calculations that indicate the usefulness of

this program as a design tool. We will also demonstrate how this tool can be employed to evaluate design schemes both for predictions about

whether comfort will be present and about energy consumption.

"'The basic mechanism for the calculational algorithm of UWENSOL

is the finite difference solution of the various energy equations used

to describe heat transfer throughout buildings. The use of the finite

difference method is in contrast to the response factor method

employed by the National Bureau of Standards and ASHRAE. We have

carefully tested the two methods against each other and have shown

that they give closely comparable results. Our preference for UWENSOL

is based on its need for reduced core space and its use-time and on

the relative ease with which pre-processing and post-processing

routines can be written for the subsequent use of this program by

architects and engineers. It has been our continuing intention

throughout the duration of this study to develop a computational tool

that can be relatively easily employed by designers as a means of

testing and evaluating their design decisions.

116
Reduction of Energy Consumption by Using a Broader Comfort Envelope

At present, in our research study we are examining the operation

of a 300-bed mental health care facility that is projected for con- struction in Steilacoom, Washington (as part of the Western Washington

State Hospital). The living and primary care areas are anticipated to

be built as a series of 25-bed modules. From programmatic data that

we have assembled, we have developed a prototypical building plan for one of these modules (for plans of one of these modules and of the

multiple arrangement of six of these modules together, see Figures 6

and 7). From this basic module, we have been carefully studying the

thermal performance of two of the specific spaces when information

such as that noted above (i.e., data about the physical forms,

schedules of use, and microclimatology) is supplied. The two spaces

being studied are a double-occupancy bedroom (a series of which are shown in Figure 6) and a day or common room (shown in Figure 8). For

detailed description of these building parts and their schedule of

use, please see Appendix A. An axonometric cut-away showing the

placement of the dayroom appears in Figure 8.

To demonstrate that energy consumption can be reduced by

employing a more broadly-defined comfort envelope, we have calculated

the heating requirements for these two spaces under four sets of

envelope boundaries: (1) ambient air temperature varying between 72

and 78°F (following the ASHRAE Standard 55-74); (2) air temperature

varying between 68 and 80°F; (3) air temperature varying between 66

and 82°F; and (4) air temperature varying between 68 and 80°F, when

the occupants are present and awake, then having the air temperature

set back to 60°F either when the occupants are present and asleep or when the room is unoccupied for extended periods of time (i.e., longer

than two hours). The first of these two spaces tested was the

double-occupancy bedroom in which the residents are presumed to be

present nearly continuously througout the 24-hour day and awake from

6 AM to 11 PM. For this situation, the results of the first three

envelope boundary conditions are presented in Figure 9. It can be seen that the second and third conditions use progressively less

energy than the first. A separate analysis shows that the fourth

condition provides results that are similar to the second for the

period when the occupants are awake, but when the occupants are asleep

and the heating system has been turned down to 60°F, there is an appreciable reduction in the amount of energy consumed for permitting

the temperature to float in the range between 68 and 60°F. Comparing

the total amounts of thermal energy required to maintain this room at

the levels set in each of the four conditions, we can see that: (1)

the amounts of energy required for the first three boundary conditions

decrease, one from the next as the temperature required is reduced

(see Figure 9); and (2) the amount of energy required in the fourth

case -- the one in which the heating system is set back at night -- is

appreciably less than the second envelope condition (the constant 68°F

temperature) and close to the amount required for the third condition

(where the temperature was held at 66°F) . For a summation of these

amounts, see Table 2. We have found that in our simulations of this room when we are employing the temperature setback condition it is

necessary to pre-warm the room by turning on the heating system one

117
FIGURE 6: A 25-bed living module for the hypothetical health facility

(letter keys appear on the following page).

118
One storey arrangement Two storey arrangement

FIGURE 7: A summary of space requirements for a 25-bed living module

(as shown in Figure 6) of the hypothetical health facility.

Letter key:

a. 10 two- bed rooms with toilet and shower 2750 sq.ft.

b. 5 private rooms with toilet and shower 1375

c. day area (or areas) 500

d. central toilet room 90

e. central bath and shower 120

f. linen 50

g. nurses station 200

h. treatment room 150

i . medication room 60

j. soiled utility 75

k. clean utility and pantry 75

1. consultation office 100

m. small conference room 120

n. storage room 100

Total assigned space for module: 5765 sq.ft.

Total assigned space for six such modules: 34590 sq.ft.

Circulation and mechanical space for six units: 1 5480 sq.ft.

GRAND TOTAL 50000 sq.ft.

119
FIGURE 8: An axonometric cut-away of a cornder of the 25-bed

living module showing a dayroom and a bedroom.

120
(niB) (U01 \aiStS ~U3INUH33U

FIGURE 9: Hour-by-hour heating loads for the double-occupancy room

121
Heating Loads Required To

Maintain The Specified

Internal Thermal Conditions Thermal Conditions *

1 . Constant Room Temperature

Minimum of 72 °F 90,236 BTU/day

2. Constant Room Temperature

Minimum of 68 °F 62,995

3. Constant Room Temperature

Minimum of 66 °F 49,425

4. Constant Room Temperature

of 68 °F from 5 AM to 11 PM

with a Temperature Setback

to 60 °F from 11 PM to 5 AM 56,663

* Results of a series of thermal simulations performed

using the computer program UWENSOL in conjunction

with the weather data shown in Figure 12 and the room description for the Double-Occupancy Bedroom,

as shown in Figure 6 and listed in Appendix A.

TABLE 2: Heating Equipment Loads for a 24-hour day for

four thermal comfort envelope conditions (for

the double-occupancy bedroom, as shown in

Figure 6)

122
hour before the occupants arise in the morning. This simulated time

of pre-warming follows actual practice in which building operators,

who employ system setback periods, switch on their heating systems an hour to two hours before the residents get up.

For the second of the two building situations -- the dayroom -- whose thermal behavior was simulated, the results of the comparisons

of energy consumption for the four operational conditions were similar

to those observed during the first set of comparisons for the bedroom.

Here again the amounts of energy required for the first three

temperature limits decrease with the reduction of the minimum

temperature permitted (see Figure 10) . The analysis of the fourth

boundary condition -- that for which a temperature setback is employed

during extended periods of non-occupancy (such as from 10 PM to

8 AM) -- indicates a marked energy savings over the comparable

situation where the temperature is fixed at a constant level over the

2A-hour day (specifically, at 68°F) . For short periods of

non-occupancy (such as from 12 Noon to 1 PM and 6 PM to 7 PM when the

occupants were elsewhere taking their meals) the HVAC system would not

be set back. The sudden rises for the required heating loads (at 12

Noon and 6 PM) reflect that, when the occupants are away from the room

and the lights are switched off, two sdl^nificant heat sources are missing and that the heating system load will thus be greater if the

system is to keep the room air temperature at a constant level. The

continuous modeling of this room over a period of several days allows

the designer to identify the effects of such short-term influences on

the thermal behavior of the room and to determine with greater assurance what HVAC system capacities are required for maintenance of

comfort.

Use of the Mean Radiant Temperature as a Means of Providing Occupant

Thermal Comfort

It may be recalled from the discussions in Sections I and II that

one of the environmental factors requiring control to insure thermal

comfort was the mean radiant temperature -- or, more precisely, the

balance of the radiant exchanges between the occupant(s) and the

building enclosure. Control of this variable is specified in the

ASHRAE Standard 55-74 . However, the Standard only states how to measure for and thus calculate this quantity, presumably after a building has been completed. Until recently, there was no accurate

method of predicting the mean radiant temperature in a building

enclosure during the designing of the building.

But with the development of a transient-state computation program

such as UWENSOL, it is now possible to predict with accuracy, during

the design phase, what the mean radiant temperatures will be within

the building spaces. To illustrate this capability, we have

determined the mean radiant temperature for a standing occupant

located in the middle of the double-occupancy bedroom. In this

demonstration we have varied the amount of glazing in the south-facing

or exterior wall, having areas equal to 157o, 50%, and 85% of this

south wall glazed with single-thickness, 1/8" double-strength clear

window glass. The room air temperature is maintained as a constant

123
(lUS) OtWl imSXS 1t£)INtK)3U

FIGURE 10: Hour-by-hour heating loads for the dayroom

124
68°F (dry-bulb temperature). As the reader may see from Figure 11,

the mean radiant temperatures over the same 24-hour period for which

the heating loads were calculated vary between about 64.2 and 66.3°F

for the three amounts of areas of glazing. If the recommendation of

ASHRAE Standard 55-74 is to be followed specifically, that for each

1°F the mean radiant temperature is below the designated termal

comfort level (here, 68°F) the ambient air temperature should be

increased 1°F to compensate -- then the air temperature for this

bedroom should be maintained at about 71°F. For the designer

confronting the condition of a too low mean radiant temperature and

wishing to provide thermal comfort, the individual might follow this one or either of two alternatives for improving the MRT levels: (1) as noted in the sentence above, raise the air temperature in the room

accordingly; (2) include in the design supplementary radiational

heating sources, such as radiant panels or architectural radiation; or

(3) improve the performance of the surfaces causing radiational

cooling by either adding insulation or mass to retard the flow of heat

outward or, such as in the case of glazing, reduce the size of window

panels or employ double or triple thickness window assemblies.

The importance of being able to predict with accuracy the mean

radiant temperatures at various locations within a building enclosure

generally is founded on the attendant comfort problems associated with

the presence of radiational heating or cooling surfaces. The problems

posed by having large glazed areas in office buildings or schools can

be avoided if designers are able to simulate the thermal behaviors of

their design schemes during the designing of these buildings and to

judge the consequences of their design decisions. Thus, no longer

should there be situations where the ambient air temperature in a space on a winter or summer day is well within comfort boundaries but

the effect of radiational heating or cooling makes the occupants

uncomfortable

.

Specification of Permissible External Design Conditions (Temperature,

Humidity, Wind Speed)

Lastly, attention should also be given to the setting of

reasonable external design conditions for use by designers when they

plan and subsequently, ^evaluate their schemes. For instance, the

ASHRAE Standard 90-75 suggests that the external temperatures used

for building envelope and mechanical system design parameters be those

designated as the 97 1/2% and 2 1/2% conditions for winter and summer,

respectively. We do not wish to debate whether these temperature

guidelines are optimal or not: it might encourage the designing of more efficient buildings, without adversely affecting occupant thermal

comfort, if instead the guidelines were set at 95% and 5%. Rather, we

do wish to emphasize that the conditions offered by the ASHRAE

Standard are for use while performing steadystate analyses. Still

another set of choices can be made when a dynamic (transient-state)

analysis is employed to compute the heating or cooling load

requirements. One method which our group has applied is to select a sequence of days -- from a taped record of weather data — during

which extreme values (both maxima and minima) of dry-bulb temperatures

125
FIGURE 11: Mean-radiant temperatures calculated for an occupant

standing in the middle of the double-occupancy bedroom

with room air temperature constant at 68OF and with

varying amounts of glazing

126
occurred. That is, we select conditions where extreme highs for summer and extreme lows for winter were recorded and where also the

rates of temperature change were extreme. Then comparisons of the

computed heating or cooling loans, given these weather conditions, are made using the UWENSOL program to perform a transient-state analysis.

The results of these comparisons have invariably shown that the loads

found using this dynamic analysis are less than those found by using

the steady-state analysis based on the weather conditions recommended

by the ASHRAE Standard 90-75 (which, in fact, were not extreme

conditions). Our procedure also provides not only the peak heating or cooling load but also an average load over the period of days

considered. The building may then be re-examined designating this

average load as the HVAC system capacity and the solution re-computed

to determine the resulting temperature excursions from optimum. From

such re-calculations the degree of thermal comfort may be established.

On the basis of this type of calulation the designer can more finely

design both the building and the mechanical system.

CONCLUSION

In this essay, we have reviewed a number of building codes and

standards with regard to the stated requirements or recommendations

for establishing occupant thermal comfort. We have noted that the

conditions set forth in the ASHRAE Standard 55-74 have generally been

employed as the basis for writing comfort guidelines in the few

standards and proposed model codes that do treat this subject. To

provide a better definition of thermal comfort conditions, findings

from studies on occupant thermal comfort which have been performed in

the United States and Denmark are described. The results of these

studies, which demonstrate very good agreement, indicate that the

comfort guidelines suggested in the ASHRAE Standard are conservative.

Alternate temperature guidelines have been noted here and we have

briefly indicated that adoption of such guidelines would result in the

conservation of energy. A number of innovative control devices and

strategies for the operation of HVAC systems have been listed;

employment of these devices and strategies are likely to improve the

operating efficiency of buildings. We have also introduced a thermal

simulation computer program, UWENSOL, which we have developed.

Applications of this program have been discussed and means for

improving the energy-efficient building and mechanical system

designing by using this program have been displayed.

ACKNOWLEDGEMENT

We would like to express our gratitude to James Bedrick for his

assistance in the performance of the computer work and to Phillip Schmidt

for his careful preparation of the graphic materials. As was noted in

the Introduction to this essay, we are four members of a twelve-person

study team; other members of this group have aided us immeasurably in

a number of ways. We are grateful for their assistance also.

127
APPENDIX A

Detailed Information About the Two Study Spaces

.^ For each room, to test its performance under varying conditions,

wei'l'first describe the room, employing the schematic program and plans

(which we had developed earlier in our research study) : the surfaces

of the room must be noted in terms of areas and compass orientations;

the presence and placement of glazing and other openings in these

surfaces need to be listed; and the choices of materials used in the

surfaces will be identified in terms of their respective placements in

the walls, roof, and floor and their properties (e.g., absorptivity,

conductivity, emissivity, specific heat, and density). Once these

data are compiled, a schedule for the use of the space must be

derived, including the occupant frequency, density, and metabolic

rate; the lighting density and when the lighting is on or off; the

amounts of ventilation and infiltration; and the interior design

temperature and humidity. Additionally, information about the

microclimatology surrounding the building must be noted, particularly

the solar radiation intensities, wind velocities, and external

temperatures and humidities. After all of this information has been

assembled, calculations can be performed to determine the amount of

heating or cooling that will be required to maintain the space within

the thermal comfort range.

Description of the Double-Occupancy Bedroom

1. Physical Presence

A. For the floor plan for this room, see Figure 6.

B. Interior dimensions = 12' wide (east-west dimension) x 10'

high X 23' deep (north-south dimension); note that the

bathroom has been lumped with the bedroom and the two spaces

are considered as one room for this analysis.

1. The south-facing plane is the exterior wall and

contains single-pane glazing of an area that is 15% of

this wall (as studied using the UWENSOL program).

2. The top plane of this room serves as both the ceiling

and the roof and, as the roof, it is exposed to the

sky.

3. The door to the bedroom (from the corridor) is located

in the north-facing plane.

4. The east and west-facing planes are interior walls

separating this bedroom from adjoining bedrooms on either side.

5. The floor is a slab-on-grade

128
C. The materials and their respective thickness are, for this

model

:

1. Floor: 4" concrete slab (140 lbs. /cubic foot); the

vinyl asbestos tile is present but has not been

considered because of its quite low resistance to heat

transfer

.

2. South wall: (a) the window area is glazed with 1/8"

double-strength, clear window glass; whether the glass

is operable is not directly considered; and (b) the

opaque area is composed of 4" face brick (placed on the

exterior), 1" polystyrene insulation, and 8" concrete

block (120 lbs. /cubic foot).

3. East and west walls and the portion of the north wall

that does not include the door: each of these consists

of 1/2" gypsum plaster (50 lbs. /cubic foot), 8"

concrete block (120 lbs. /cubic foot), and 1/2" gypsum

plaster

.

4. Door: 6'8" x 3' solid-core wood door.

5. The ceiling/ roof plane consists of, from the inside to

the outside: acoustic tile, 4" of lightweight (perlite)

concrete (40 lbs. /cubic foot), and built-up roofing.

Schedule of Use

A. Occupancy : Two adults will be present, for this model, con- tinuously throughout the 24-hour period studied. The

metabolic rate is fixed at 400 Btu/hr/occupant

.

B. Lighting : The lighting level in the room has been set at

1.5 watts/square foot of floor area as a constant artificial

illuminating intensity. This is equal to, for the bedroom

floor area of 182 square feet, 931 Btu/hour. The artificial

illumination is presumed to be switched "on" continuously

from 6 AM to 11 PM. For this model, opportunities afforded

by natural illumination were not included as a means of

meeting lighting needs.

C. Ventilation Rate : The ventilation air is provided

continuously and is based on the guideline of 10 cubic feet

of supply/minute/occupant. Thus, there is a constant supply

of 20 CFM. One-half of this supply is fresh air taken from

outside of the building. The overall temperature of the

supply air is 74°F.

D. Infiltration Rate : Infiltration is expected to occur at

about 1/2 air change/hour or about 15 cubic feet/minute.

This rate is based on the expectation that the glazing is

either not operable or is partially operable with a careful

application of weatherstripping

.

E. Other measures : The ground temperature underneath the slab

has been set at 60°F to recognize that the ground underneath

such a slab would gradually be warmed by the heat that is

transferred through the slab over time.

129
III. Weather Data

A graph of the diurnal temperature cycle and the solar insolation

for the reference day appears as Figure 12. The solar insolation

is a sum of the direct solar radiation, the diffuse radiation

from the sky hemisphere, and the reflected radiation from the

ground and surrounding objects (e.g., buildings, vegetations,

etc.) The reference day is the second day of a winter sequence

of measurements taken for a four-day period at the McChord Air

Force Base in 1961. These data are representative of wintertime

weather conditions in the Puget Sound area.

Description of the Dayroom

I. Physical Presence

A. For the floor plan for this room, see Figure 8.

B. Interior dimensions = 16' wide x 16' deep x 10' high.

1. Both the south- and west-facing planes are exterior

walls and contain single-pane glazing with areas equal

to 30% of each of these walls (as studied using the

UWENSOL program) , The total glazing area is presumed

to be equally distributed between these two exterior

walls

2. The top plane of this room serves as the ceiling-roof

and its top is exposed to the sky. A flat roof is

used

3. The door to the dayroom (from the corridor) is located

in the east wall.

4. The north and east planes are interior walls separating

this dayroom from adjoining bedrooms on either side.

This dayroom is deployed as a corner room of the living

module

5. The floor is slab-on-grade

C. The materials and their respective thicknesses are, for this

model, entirely similar to those identified for the

Double-Occupancy Bedroom.

II. Schedule of Use

A. Occupancy : Ten (10) adults will be present, for these calculations, during the following hours -- 8 AM to 12 Noon; 1 PM to 6 PM; and 7 PM to 10 PM. The metabolic rate for these

adults is fixed at 400 Btu/hour/occupant

B. Lighting : The lighting level in the room has been set at

2.0 watts/square foot of floor area as a constant artificial

illuminating intensity. The artificial illumination is presumed to be 1/2 on during the period when there is solar

radiation (from 8 AM to 4 PM) and when the room is occupied

130
S 9 ^

(J 030) 3iruuiQ<«aL 9TB;kiia aiisino

tu esAus) NoutnosNi

FIGURE 12: Outside air temperature and insolation

incident on the external surfaces of

the bedroom and dayroom

131
(as identified in 11. A. above). When there is no solar ra- diation, the lights are said to be operating at 100% of

capacity. When the room is unoccupied (again, as identified

above), then the lights are presumed to be off.

C. Ventilation Rate : The ventilation air is provided

continuously throughout the 24-hour period at a rate of 150

cubic feet/minute. At least 66% of this supply is fresh air

taken from outside of the building. The overall temperature

of the supply air is set at 74°F.

D. Infiltration Rate : Because the building has an appreciable

positive ventilation rate, the infiltration rate is presumed

to be minimal and can be neglected.

E. The other measures noted for the calculations for the

Double-Occupancy Bedroom are in effect for this room also.

III. Weather Data

The weather data noted above for the Double-Occupancy Bedroom are entirely identical for this Dayroom.

132
REFERENCES

1. ASHRAE Standard 90-75, "Energy Conservation in New Building

Design," ASHRAE, 345 East 47th Street, New York, New York 10017,

1975.

2. Uniform Building Code , 1976 Edition, International Conference of

Building Officials, Whittier, California, 1976.

3. Uniform Mechanical Code , 1973 Edition, International Conference

of Building Officials, Whittier, California, 1973.

4. ASHRAE Standard 55-74, "Thermal Environmental Conditions for

Human Occupancy," ASHRAE, 345 East 47th Street, New York, New

York 10017, 1974.

5. ASHRAE Standard 62-73, "Standards for Natural and Mechanical

Ventilation," ASHRAE, 345 East 47th Street, New York, New York

10017, 1973.

6. "Energy Conservation Standards for Non-residential Buildings"

(Staff report prepared by the Energy Resources Conservation and

Development Commission, 1111 Howe Avenue, Sacramento, California

95825), May 1977.

7. "Model Code for Energy Conservation in New Building Construction"

Prepared by the National Conference of States on Buildine Codes

and Standards, 1970 Chain Bridge Road, McLean, Virginia 22101

Preliminary Draft for Review, January 1977.

8. Nevins , R. G. "Psychrometrics and Modern Comfort" (Presented at

the joint ASHRAE-ASME meeting, November 28-29, 1961). Reference

taken from the ASHRAE Handbook of Fundamentals , 1972 Edition, 345

East 47th Street, New York, New York 10017, 1972. Page 136.

9. Newburgh, L. H. (editor). Physiology of Heat Regulation and The

Science of Clothing . New York: Hafner Publishing Company, 1968.

10. Hill, J. E., T. Kusuda, S. T. Liu, and F. J. Powell. A Proposed

Concept for Determining the Need for Air Conditioning for Build- ings Based on Building Thermal Response and Human Comfort . (National Bureau of Standards Building Science Series 71).

Washington, D.C.: U.S. Government Printing Office, 1975.

11. Givoni , B. Man, Climate and Architecture , Second Edition. London:

Applied Science Publishers, Ltd., 1976.

12. Houghton, F. C. and Yaglou, C. P. "Determining Lines of Equal

Comfort," ASHRAE Transactions 29 , 1923. Pages 163ff.

13. Nevins, R. G. , F. H. Rohles, W. Springer, and A. M. Feyerherm.

"Temperature-Humidity Chart for Thermal Comfort of Seated

Persons," ASHRAE Transactions 72 , 1:283-291, 1966.

133
14. Rohles, F. H. , Jr. "The Model Comfort Envelope: A New Approach

Toward Defining the Thermal Environment in Which Sedentary Man is

Comfortable," ASHRAE Transactions 76 , 11:308-317, 1970.

15. Fanger, P. 0. Thermal Comfort: Analysis and Applications in

Environmental Engineering . New York: McGraw-Hill Book Company,

1972.

16. McNall, P. E., Jr. J. Jaax, F. H. Rohles, R. G. Nevins , and W. Springer. "Thermal Comfort (Thermally Neutral) Conditions for

Three Levels of Activity," ASHRAE Transactions 73 , 1:3.1-1:3.14,

1967.

17. Gagge, A. P., J. A. Stolwijk, and Y. Nishi. "An Effective

Temperature Scale Based on a Simple Model of Human Physiological

Regulatory Response," ASHRAE Transactions 77 , 1:247-262, 1971.

18. Hardy, J. D. "Thermal Comfort and Health" (Presented at the

Second Human Factors Symposium, 1970 ASHRAE Semi-Annual Meeting,

1970)

Reference taken from Gagge, A. P. et al (17). Page 255.

19. Gagge, A. P. and Nevins, R. G. "Effect of Energy Conservation

Guidelines on Comfort, Acceptability, and Health" (Final Report

on a Series of Laboratory and Field Studies prepared for the

Federal Energy Administration by the John B. Pierce Foundation

Laboratory, 290 Congress Avenue, New Haven, Connecticut 06519,

March 1976.)

20. Steadman, P. Energy, Environment and Building . Cambridge,

England: Cambridge University Press, 1975.

21. Stein, R. G. Architecture and Energy . New York: Anchor Press,

1977.

22. Emery, A. F. , D. R. Heerwagen, C. J. Kippenhan, S. V. Stoltz, and

G. B. Varey. "The Optimal Energy Design of Structures by Using

the Numerical Simulation of the Thermal Response -- with Emphasis

on the Passive Collection of Solar Energy," (in preparation).

134
IMPLEMENTATION OF ENERGY CONSERVATION BUILDING STANDARDS

THE VERIFICATION PROBLEM FOR HVAC SYSTEMS

by

Daryl E. Tonini

Technical Director

Associated Air Balance Council

Washington, D. C.

and

Thomas E. Sluiter, AIA

Technical Coordinator

Construction Research Council

Washington, D. C.

This paper outlines the parameters and procedures which should be

considered in the preparation of energy conservation performance

specifications and verification for building mechanical systems.

The trend toward implementation of energy conservation standards,

particularly for commercial building, carries with it the question of

how the building code official is to determine whether or not an energy conservation standard has been met. For prescriptive

standards, e.g. insulation thickness requirements, this may be readily

ascertainable. For performance standards for HVAC systems, this

becomes a very significant problem for the code writer as well as the

building code official.

It has been shown that significant energy savings may be achieved

by careful balancing and optimization of building mechanical systems

for new buildings or retrofit of existing inefficient systems. It is

anticipated that code writers concerned with energy conservation

standards may wish to address this important subject area in their

codes

.

Key Words: Balancing; building code official; code requirements;

' energy conservation; performance specifications;

testing; verification.

135
INTRODUCTION

The historic role of testing and balancing of HVAC systems

process has been to establish for the building owner whether or not

HVAC contractual provisions have been satisfied. However, the

technical expertise required in this traditional role, along with the

requirements for proficiency and independence of the testing agency

from other contractual interest in the HVAC system is being called

on by the architect-engineer and building owners to assess the

effectiveness of energy conservation measures.

The trend toward implementation of energy conservation standards,

particularly for commercial building, carries with it the question of

how the building code official is to determine whether or not an energy conservation standard has been met. For some equipment and

materials, this may be fairly straightforward, particularly as pertains to laboratory test certifications for furnaces and appliances

and for materials with prescriptive standard specifications e.g.,

insulation thickness requirements.

However, in the area of performance standards involving heating,

ventilating and air conditioning (HVAC) systems this can become a very

significant problem. This paper outlines parameters and procedures

which should be considered in the preparation and verification of

energy conservation performance standards for building mechanical

systems

PERFORMANCE STANDARDS AND HVAC SYSTEMS

In considering the overall problem of energy conservation measures as they relate specifically to the HVAC systems in other than

residential buildings, there are several considerations which deserve

mention.

(1) There is a need to upgrade existing buildings and their

systems to modify their energy consumption patterns to more acceptable levels. This, in general, will consist of

modifying the building envelope in some manner to increase

its energy efficiency and/or adjusting the mechanical system

to provide optimum efficiency.

(2) For new construction, energy saving features may be

incorporated into the design to include specific

requirements regarding insulation, luminaire and solar heat

build-up, and energy efficient HVAC systems. More and more,

these requirements are being made a part of building codes

through adoption of energy-related standards and model codes

such as found in American Society of Heating, Refrigerating,

and Air-Conditioning Engineers (ASHRAE) Standard 90-75,

136
"Energy Conservation in New Buildings," and the Building

Officials and Code Administrators (BOCA) , "Basic Energy

Conservation Code/1977." The BOCA model code incorporates

all applicable energy conservation requirements presently

included in the BOCA "Basic Building, Mechanical, and

Plumbing Codes" and incorporates the energy conservation

requirements of ASHRAE 90-75. In addition, the Construction

Research Council, representing institutional building owners,

is addressing itself to specifications which will define

requirements for performance and testing of HVAC systems.

(3) In the case of HVAC equipment and systems, the mere adjustment of an individual component may not, of itself,

achieve a great deal. The "total" adjustment of the system

can achieve major energy consumption improvements. This is

based upon an understanding and appreciation of the prime

definition of climate conditioning to be the process of

treating air so as to control, simultaneously, the

temperature, humidity, movement, cleanliness, and final

distribution to meet the requirements of the space to be

conditioned. While the individual air treatment processes

contribute a specific element in producing human comfort, in

practical applications, it is the composite effect of all of

these processes, each related to and influencing the other,

that produces the final desired conditions. If any element

of the system is not functioning and performing as it

should, the final result will be effected in terms of energy

efficiency and overall system performance. The process for

producing this coordinated function is referred to as HVAC

system balancing. (It must be noted that there are definite

engineering and physiological trade-offs involved in meeting

requirements for the "people environment" as opposed to

those representing the optimum energy efficiency of a system.

)

All of which suggests the following:

(1) That energy performance of new buildings must ultimately be

measured by some performance criteria which addresses the

total system.

(2) That some datum is necessary against which to measure the

effectiveness of changes to existing buildings.

ACHIEVING ENERGY EFFICIENCY FOR HVAC SYSTEMS

A well-tuned HVAC system, which like a properly tuned automobile,

will use less energy to fulfill the purpose of design and at the same

time cost less to operate. In the case of HVAC systems, a well-tuned

system means a well-balanced system. Turning down thermostats or raising cooling thermostat settings will not make any appreciable

difference in energy conservation except perhaps in small, package

type residential systems. This argument is supported in part by

Snell, Kusuda, and Didion's review of the general data from Project

137
Independence and ^^er sources on energy use in the United States

office buildings. In one building site as an example, energy

reductions related to system adjustment were essentially achieved by

discipline in the use of lighting systems. For the same time period

the energy consumption by fans and pumps, cooling, heating, and hot

water was actually slightly higher, possibly as the result of reducing

the heating provided by the luminaires. However, this same data

suggests that major energy reductions are achievable if HVAC system

performance is optimized for efficiency.

(3) As pointed out by Liu, Hunt, and Powell, the energy used for

space heating and cooling, lighting, hot water heating, and mechanical

ventilation constitutes a large portion (32 percent) of energy

consumption in the United States. They note that it has been

estimated that at least 10 to 20 percent and maybe as high as 40 to 50

percent of the energy used in buildings could be saved in the design

and construction of new buildings. This could be achieved by

performing a comprehensive thermal analysis of the building envelope,

by a more careful evaluation of fresh air ventilation and lighting

requirements, and by the utilization of efficient energy conversion

equipment

For existing buildings, implementation of HVAC energy

conservation code requirements may impose special considerations.

These are outlined elsewhere in this paper. However, there are a number of actions which may be undertaken voluntarily at the option of

the owner or mandated by the code pending development of more definitive standards such as proposed in ASHRAE Standard 100. 4P,

"Energy Conservation in Existing Buildings -- Industrial." Among the

energy improvement actions which are currently^ .available under

Associated Air Balance Council (AABC) procedures and which may be

applied at the option of the owner by the test and balance engineer

working under the direction of a professional engineer are:

(1) Evaluation of the return air system for use of an economy

cycle using outside air for cooling when the ambient

temperature is between 40°F and 50°F.

(2) Measurement and evaluation of the water discharge

temperature of the chiller and boiler to ascertain the

feasibility of raising the chiller discharge temperature and

lowering the boiler discharge temperature by a few degrees.

(3) Checking amperage demand of motors. If running overamped,

they can possibly be adjusted downward by reducing fan speed

by as little as 5 to 10 percent. In conjunction with the

implementation of other energy conservation measures, it may even be possible to reduce fan motor size while still

achieving desired performance.

(4) Heating and cooling coil surfaces should be inspected and

cleaned thoroughly to prevent static pressure build up which

produces extra fan loading and needless energy waste by the

motor.

138
(5) Checking all pumps for proper head pressures and adjusting

motor amperages to the most efficient settings.

(6) Checking the system for proper maintenance: inspect coolant

for Slgae or slime which reduces heat transfer efficiency

causing circulating pumps to work harder and wasting energy;

clean strainers and check pipes for calcified deposits which

reduce pumping efficiency.

(7) For systems containing several motors of the 10-50

horsepower class, evaluate and consider modification of the

control system to provide step-starting to reduce peak power

demands. If several chillers are used, consideration should

be given to programming loan demand to give an optimum load

to each chiller.

(8) Where natural gas fired boilers are used, pressure

regulators should be tested to determine proper calibration.

Fuel to air mixtures should be checked for' most efficient

combustion.

One point worth mentioning here is that some systems have never been properly tested, adjusted, and balanced. This, possibly, because

it was felt that it was an unnecessary expenditure when the system was built and eliminated to save a few dollars on the initial cost of the

building. It is on these buildings that the greater savings will be

realized by applying good analysis procedures followed by expert test

and balancing.

On other systems which have been balanced originally, it must be

remembered that most were balanced before the energy crisis and at

that time they may have been balanced to meet design criteria

established by the plans and specifications for optimum performance

and not optimum energy efficiency. To illustrate this point, many

systems designs can be reevaluated to see where energy savings can be

achieved through reduction of air volumes. It should be borne in mind

that when heat generating systems are cut back or shut off to conserve

energy, large reductions occur in the cooling demand which represents

a major energy saving. Once cooling loads are reduced, air quantities

can often be reduced. This, in turn, may require changes in air flow

distribution patterns or redistribution of air to different zones. Damper settings may have to be adjusted to provide for the adjusted

heat loads throughout the building.

MEASURING PERFORMANCE

Regardless of whether prescriptive or a performance specification

is prepared, probably the major problem lies in determining whether

the specification has been met. At the most elemental level, in

dealing with a prescriptive specification the inspector's task is

reasonably straightforward, e.g. measuring the inches of insulation,

U factor, checking documentary of laboratory testing requirements for

furnaces and other appliances. Unfortunately, this level of

139
compliance determination suffers serious deficiencies with regard to

evaluation of system performance or overall energy effectiveness of a given structure. It is even possible to conceive of the case whereby

a building modification to improve energy efficiency would, in terms

of the overall system, have a negative effect on the energy efficiency

of the structure.

This question of determining the effectiveness (and compliance

with code requirements) of an energy improvement measure is quite

complex. It has been addressed by the Federal Energy Administration

(FEA) in proposed rules and public hearings of Energy Audit

Procedures. In its testimony before the FEA at the public hearings

in Washington, D.C. on the proposed rules, the Associated Air Balance

Council made the following observations:

(a) There is a real need to protect the building owner or buyer

from the overzealous supplier who may make energy

performance claims which cannot be fully justified. The

point being that, in general, neither the buyer/owner or the

building code official may be in the position to evaluate

the claim of the effectiveness of a given energy

conservation technique as it applies to a given building.

Some mechanism for qualified independent audit is required.

(The proposed FEA approach is to develop a system to provide

for an independent outside audit to establish compliance

with performance criteria.)

(b) The FEA proposed rules tend to view proposed energy

improvement techniques in isolation from the total system

effects. AABC pointed out the serious pitfalls which await

the unsuspecting as pertains to failing to consider the total

HVAC system and not an isolated element or proposed

improvement. We feel that element or subsystem optimization

is potentially poor engineering and economic practice.

(c) The proposed rules do not include operating and maintenance

costs in total purchase and installation cost in their life

cycle cost calculations for energy effectiveness. While

this may be difficult to relate to the building code

official's area of interest, it does bring up the point that

judging or approving an energy conservation measure solely

on the basis of first cost is an extremely questionable

procedure

(d) In addressing the FEA recommendations of qualifications for

certifiable energy auditors, the Associated Air Balance

Council suggested that industry certifications such as those

required for an AABC Test and Balance Engineer qualification

be accepted by the FEA. This suggestion is consistent with

the recommendation of the Building Resgarch Advisory Board

of the National Academy of Sciences for test and

balancing of HVAC systems:

140
"...The contract should specify that the adjusting,

balancing, and testing services must be performed by an independent organization which in no way is affiliated

with either the prime contractor, the installing

mechanical equipment contractor, or manufacturing of

equipment used in the environmental system, or the

engineering firm responsible for the design of the

system. .

.

"...contracts should stipulate that in order for a firm

to qualify as an independent testing and balancing

organization, it must either be a member of the

Associated Air Balance Council or meet the criteria

membership in the AABC..."

PE AND TEE RELATIONSHIPS

As can be gathered from the preceeding discussion, HVAC system

performance measurement and corrective diagnosis represents a fairly

sophisticated interdisciplinary activity involving building code

officials, owners, the architect-engineer with his professional

engineer (PE) staff specialists, and the test and balance engineer

(TEE). In those cases where the Associated Air Balance Council

certified TEE is also a PE and in a position to take on the PE

responsibilities, the communication process is simplified. However, in

general this may not be the case.

NEW CONSTRUCTION

Assuming that building energy code certification is required and

presented, the code official should determine if the certification has

been signed by an independent and qualified test and balance agency.

If the certification was by such an agency, the building code official

may accept the architect-engineer's certification. If the

certification was not signed by an independent, qualified test and

balance agency, the building code official should call for a certification signed by a TEE or equivalently qualified engineer. If

the construction is presented for code approval without an energy code

certification, the code official should require the A/E to obtain the

HVAC energy certification. Alternately, the building code official

may go directly to a TEE agency and request that the tests prescribed

in the code are conducted.

EXISTING CONSTRUCTION

For existing buildings, the case may be complicated by either or both conditions where the energy code for new construction may not

apply and where the original HVAC construction specifications are not

available. Even if the construction specifications are available,

changes to the building configuration, equipment, and usage may have

rendered the original specification meaningless.

141
If the construction specifications are available (and relevant to

current operating conditions) a TBE audit could be performed. This

audit should then be placed in the hands of a mechanical system PE who

would evaluate the HVAC system performance and direct any necessary

modifications to bring the system up to code standards. Once this

work is completed, the TBE should again be brought in to certify HVAC

system performance.

If construction specifications are not available, the PE and TBE

working together as a team should evaluate and document the mechanical

system in situ . A TBE audit may be an integral part of this joint

effort. The PE would prepare a HVAC system modification plan; the

desired modifications completed by a mechanical contractor, followed

by TBE certification of system performance.

ENERGY CONSERVATION CODES INVOLVING HVAC SYSTEMS

There appears to be an unquestioned need to improve code

requirements for both new and existing construction as pertains to the

energy conservation problem facing most if not all governmental

levels. For residential construction and small commercial buildings,

the trend may well be toward the prescriptive code or specification.

For commercial buildings this refers to cooling - engineering

considerations probably dictate a strong movement toward performance

codes and specifications.

The problem is that although development of HVAC performance

specifications is well advanced as the result of efforts of groups

such as the Construction Research Council, the development of total

building system energy performance specifications is very much in an embryonic state. Excellent work in this area is proceeding under the

direction of the Center for Building Technology, National Bureau of

Standards. Energy models for complete building systems are being

investigated to determine the degree of interaction between subsystems

and to develop the necessary mathematical relationships to define

these interactions in terms of building design and performance.

The status of development of energy performance specifications

for larger buildings notwithstanding, it appears that there is still a great deal which the code writer can do to deal with this problem at

the local/municipal level. Assisting with this process is the

self-interest of design professionals and building owners to develop

energy efficient designs for both new and existing buildings. In most

areas, the cost for energy is probably sufficient to serve this

self-interest. However, the commercial real estate speculator may not

perceive the needs of the ultimate building owner and could easily

decide not to willingly seek out or demand an energy-efficient design

(with its attendant added costs). Likewise, some owners of buildings

with tenants may be tempted to pass on the costs of their building

inefficiencies to their tenants. The code writer clearly needs tools

to deal with these latter conditions, if only to serve the total

interests of his jurisdication during energy restricted periods as were experienced in many parts of the United States during the winter

142
of 1976-77. Fortunately, most codes have provisions for 3rd party

certification and/or give the necessary authority to the building

official to implement necessary action. This authority can be used to

obtain field testing services. However, in general, it appears that

the building official relies heavily on the plan checking phase

supported by comprehensive data submitted by the designer.

For new construction, it is encouraging to note that community

energy consumption norms are being developed. Most logically, this

will be achieved through a study of energy consumption levels as they

relate to specific building classifications. In conjunction with the

local municipal building engineering staff and design professionals,

design objectives can be agreed to, studied on a voluntary basis for some time period, and then finalized as local code requirements. It

must be borne in mind that a properly balanced HVAC system, even without extensive building and equipment modifications, will produce

substantial energy savings. This certainly should be given priority

consideration for code adoption.

For an existing commercial building (with over 100 tons of air

conditioning) consideration should be given to a phased-in requirement

that the HVAC system be balanced for optimum energy efficiency which

would meet nominal comfort standards. This requirement would

establish an invaluable datum to assess the improvement in energy

efficiency resulting from any other energy conservation measure

applied to the building. Some of the steps in that procedure were outlined earlier in this paper. A requirement for subsequent audits

may be considered following any major changes to the energy envelope.

SUMMARY

The state-of-the-art having reached the level which would allow

codification of a definitive energy performance specification, there

is now enough information available to allow the code writer, in

conjunction with his engineering staff and local design professionals,

to take the first step in substantially improving the energy

efficiency of many larger buildings which may not be suited to

prescriptive energy specifications.

One of the readily achievable payoff areas would be in improving

the efficiency of mechanical systems for both new and existing

structures. Much is achievable when the unique talents of the design

engineer and test and balance engineer are brought together to address

this problem.

We commend these thoughts and recommendations for your

consideration.

143
REFERENCES

1. "Resolution and Code Requirements for the AABC Certified Test and

Balance Engineer," National Examining Board of United States and

Canada, Associated Air Balance Council, Washington, D.C. 20005.

2. Snell, J. E., Kusuda, Tamani and Didion, D. A., "Energy

Conservation in Office Buildings: Some United States Examples,"

PB-260901, 1976, National Bureau of Standards, Washington,

D.C. 20234.

3. Liu, S. T., Hunt, C. M. , and Powell, F. J., "Evaluation of

Ventilation Requirements for Energy Consumption in Existing New

York City School Buildings," NBS Building Science Series 97,

1977, National Bureau of Standards, Washington, D.C. 20234.

4. "National Standards for Field Measurements and Instrumentation,"

1974 Second Edition No. 12173, Associated Air Balance Council,

Washington, D.C. 20005.

5. Federal Register FEA Energy Audit Procedures - (10 CFR Part 450)

6. "Adjusting, Balancing, and Testing of Building Environmental

Systems," Federal Construction Council Technical Report No. 59,

1971, National Academy of Sciences, Washington, D.C. 20418.

144
SYSTEMATIC ORGANIZATION OF STANDARDS AND CODES

by

James R. Harris and Richard N, Wright

Center for Building Technology, lAT

National Bureau of Standards

Washington, D.C.

The ease and confidence with which a code or standard can be used

depends on how well it is organized. A systematic method for organization of design standards and codes is described and illustrated with

an example. The method provides checks on the uniqueness and completeness

of the organization, where organization is taken to include both the scope

and the arrangement of the provisions. The method promotes the use of

technically valid provisions and improves the efficiency of standards

generating activities. The illustrative example is the organization of

a performance specification for the structure of residential buildings.

The method is based upon objective qualities of an organization.

The key element of the method is the systematic classification of provisions. Each provision is related by its syntax and semantics to

several classifiers. Requisite properties of uniqueness and completeness

are achieved in the overall organization by requiring them in subsets

of the classification and then building the overall organization in a systematic fashion.

Key Words: Building codes; classification; index; organization; outline;

standards; systems engineering.

145
INTRODUCTION

A designer or regulator who refers to a code or standard must be

able to find with ease and confidence the provisions he needs. Regulators are reluctant to accept new technology in codes and standards,

in part, because they cannot be confident of finding the correct provisions. Designers are reluctant to use unfamiliar codes and standards,

often because it is hard for them to find and to be sure they have

found all the relevant provisions. The organization of provisions

determines whether they can be efficiently and reliably found by the

reader

This article briefly describes an innovative method for outlining that provides a systematic and effective method for organizing

standards or codes. An example reorganization of a set of provisions

illustrates many important features of the method. Writers of provisions benefit by using the method because their task becomes more

systematic, thereby possibly easier and more efficient. Designers

or regulators benefit in the sense that they find it easier to locate

pertinent provisions and they have assurance that the set of provisions

is complete.

The procedures encourage a consistent treatment of and explicit

decisions about scope and arrangement by the writer. An outline of

classifiers (keywords) is constructed, then converted to an outline

of provisions. Deciding upon what classifiers to use constitutes an analysis of scope, while deciding how to make an outline of the

classifiers constitutes an analysis of the arrangement.

Provisions are classified according to their meaning (semantics)

and structure (syntax). Explicit checks are made for completeness,

clarity, and correctness in the set of provisions. The use of performance related classifiers assures that the reason for each provision

is understood, even if it is not expressed in the final text. The

outline assures that the set of provisions covers the scope, and provides an unambiguous location for each provision based on its subject

matter so clear access is promoted.

BACKGROUND

Difficulty in finding relevant provisions is one of the problems

that the format and expression of codes and standards can present to

their readers. Errors also can arise from ambiguities and incompleteness

in individual provisions and from missing or misinterpreting the re- lations between provisions. The outlining method is one part of a three part system for systematically analyzing and representing codes

and standards in order to minimize these problems. The other two are:

a decision table for dealing with the meaning of individual provisions

and an information network for dealing with the precedence relations

between provisions.

146
Decision tables and information networks were defined and their

use was illustrated by Harris (1)* at the First NBS/NCSBCS Joint Conference

in 1977. They can be briefly defined as follows:

1) The decision table is used to express the functional and logical

relationships that establish the value for each data item that

is defined in the document. A decision table is simply an orderly presentation of the reasoning controlling a set of

decisions. It is easily analyzed to assure that the reasoning

process will always lead to a unique result and that no possibility exists for encountering a situation not defined. Another

advantage of decision tables is that they require an overall

analysis of situations involving parallel thought processes

whereas written text, and to some extent, flow charts both

describe more of a sequential thought pattern.

2) The information network is used for reference to the other items

of data that may be required in the evaluation of any data item.

It gives a clear expression of the relations between provisions.

Each data item is a point, or node, on the network. The nodes

are connected to their ingredient nodes by branches that re- present the flow of information through a set of provisions from

the input data items to the terminal criteria. The ingredients

of a node are defined as all those data items that may be re- quired for direct evaluation of the node. For example, the

allowable story area and the actual story area are ingredients

to the provision that ". . .no floor shall have an area greater

than the allowable area ..."

Fenves and Wright (2) concisely describe the concepts and principles

underlying the entire system, Harris et al (3) illustrate the use of each

of the systems with and without computer aids, and Pollack (A) explains

decision tables in detail. Work has been underway at the National

Bureau of Standards (NBS) for about two years to improve the outlining

method over that of reference 3. The example used in this report has

served as one of several case studies in this effort. A full report

describing this technique in more detail will be available from NBS

in the near future.

BRIEF DESCRIPTION OF THE OUTLINING METHOD

The basic tools for locating provisions within a code or standard

are the table of contents, headings printed within the text, the index,

and internal cross references. The first three of these are lists of

headings. A heading should relate meaningfully to the provisions

beneath it so that the reader can find the provisions. The technique

presented here for organization of standards accomplishes this by com- posing headings of one or more classifiers. The fourth tool, cross references, is an instruction from one point in the text to refer to

another section, or heading. Cross references between related provisions are provided for in the information network system mentioned

previously.

*The numbers in parentheses refer to the citations listed in References.

147
The outlining method that organizes the headings is founded upon

the proper relation of classifiers to provisions and to other classifiers.

The relations occur at three levels: between individual classifiers and

provisions, between individual classifiers within one class, and between

different classes of classifiers. For example, the provision "the structural system shall safely support all loads expected during its service

life" is related to the classifiers structural system, safety, and load.

Each of these classifiers is related to similar classifiers, for example,

safety is a member of a class of values such as durability, serviceability,

and so on. In addition, there are relations between different classes

for various reasons such as cause and effect or a need for finer distinction; for example, collapse is a member of a class of events that all cause the loss of some value in the class containing safety. Objective

principles governing these relations have been derived from the following

qualities desired in a final organization:

1. Qualities necessary for a good organization:

Relevant ; Each heading must be significantly relevant to its

provisions; it must concisely express their scope.

Meaningful ; The intended readers must perceive the heading as being relevant.

Unique ; The headings must be distinct from one another to allow

readers to access provisions unambiguously.

Hierarchial : The headings at any level must be progressively

ordered in a pattern significant to the reader and the headings

must show a regular gradation in scope through the levels.

Complete ; The total set of headings must cover the entire scope

of the set of provisions and nothing more.

2. Qualities desirable for a good organization:

Minimal ; The headings should be permuted so that the number

of headings is the minimum for meaningful access.

Even : The organization should divide the provisions so that

depth (the number of levels in an organization) and breadth

(the number of headings at one level) do not vary greatly from

one part to another.

Intelligible ; The depth and breadth should not exceed the average

span of immediate memory of the reader.

The relation between classifiers and provisions must provide relevant,

meaningful headings. An analysis of the language of performance standards

by Fenves, Rankin, and Tejuja (5) showed that performance type provisions

have a small set of basic linguistic structures. In these structures,

the subject of a provision typically names some physical entity while

the predicate gives some desired characteristic; and frequently, the

circumstance in which the characteristic is desired. Thus, it is relevant

148
to class a provision by its physical entity and desired characteristic;

for example, structural system and safety. The writers have extended

this classification to cover all types of standards and provisions related to buildings. Examination of a large number of provisions in

building regulations and study of several other systems of classification

for building technology (6, 7) shows that the generic structure given in

Table 1 is capable of encompassing a complete, relevant set of classifiers.

The following are definitions and examples of some of the basic classes

from the table:

THINGS - the objects, processes and events referred to in provisions.

Physical Entity - the systems, objects, parts, and materials that

make up buildings, from bolts to structural systems, svjitches to

electrical systems, and so on.

Human Entity - the agents of the construction process, such as designers,

builders, and regulators, and the users of buildings.

Phenomenon - a response of a physical entity to the actions of

its environment such as weathering, rotting, deflection, creep,

cracking, etc. A particularly important subclass is termed

LIMIT STATE which is defined as an event that causes the loss

of a performance attribute either by the occurrence of the event

(e.g., collapse) or by the magnitude of the response (e.g.,

excessive deflection)

.

Process - the activities involved in the design, construction,

regulation, and use of buildings.

Environment - the circumstances in which physical entities exist

such as exposure to wind, to corrosive attack, to imposed distortions, etc. This class, as well as several of the others, can

serve two functions in provisions: to define the particular

physical entity or process being addressed by the provision or

to prescribe a desired characteristic.

QUALITIES - the characteristics of things referred to in provisions.

Physical Quality - size, weight, color, strength, location,

time, etc. are among the many physical descriptors that can be

used both to define entities or to mandate characteristics.

Social Quality - qualities, characteristics, or attributes

of a thing that relate to human needs, aspirations, uses, and

interactions. One subclass that is mandatory in performance

standards and highly desirable in all standards is PERFORMANCE

ATTRIBUTES which are the important qualities that are necessary

to fulfill the needs of the building occupants, neighbors, owners,

and society as a whole such as safety, functionality, durability,

etc. Another common subclass is FUNCTION which is the intended use of a physical entity or process. There is a close relation

between function, performance attribute, and environment; function

generally having a strong influence on the latter two.

149
As a classification system for any particular code or standard is

developed, many of the above classes will be used. As a minimum, one

class of thing for subject and one class of quality for predicate will

be necessary. Generally, many subclasses will be used to define the

scope in the intricate fashion typical of today's codes and standards.

The objective qualities of the organization, presented previously,

become principles to guide the construction of the classification, as briefly explained in the following paragraphs.

First, the system must contain all classifiers relevant to each

provision so that the index will be complete. Thus, any classification

for a performance standard must contain a class of physical entities

to serve as a subject, a class of performance attributes to serve as predicate for the performance requirements, and a class of limit states

to serve as predicate for the performance criteria because of the basic

structure of performance statements identified in reference 5. A

classification of prescriptive criteria will typically be dominated by

very detailed classes of physical entities for the subjects and physical qualities for the predicates. Note that from the set of all

classifiers relevant to a provision, it appears to be possible to

construct the provision by applying appropriate rules of syntax.

Although these rules of syntax have only been identified for performance

requirements and performance criteria as described by Fenves et al (5)

and although the provision thus constructed might not be complete

because numerical and Boolean values would not come from the classifiers,

the concept does lend considerable rigor to the outlining method.

The individual classifiers must also be meaningful; that is, the

intended readers of the provision must reliably associate the classifier

with the provision to guarantee clear access to the correct provision.

As classes of classifiers are formed, the members of the class must be

mutually exclusive at any level to guarantee unique headings for unam- biguous association of the provision to a heading, and they must be

collectively exhaustive to guarantee completeness. The classifiers

within a class and the relations between classes must be hierarchical

in order to maintain the uniqueness and completeness as outlines are developed from the classifiers and to provide headings that are progressive and graded. The entire set of classifiers must be complete

and unified. That is, all classifiers necessary to define the scope

of the set of provisions must be present, and all classifiers present

must be significant to the scope.

Once the classification is established, it is possible to develop

outlines of classifiers by using a routine that develops a network from

the various classes. It is possible to develop several different outlines from the same classification, and then select the one which appears

best for the intended use. The routine, which can be executed using a computer, will not be discussed in this report but can be found in reference 3 and will be discussed further in a future NBS report. The

rationale for selecting one outline over another is based on the desired

qualities of minimal, even, and intelligible described previously.

150
CASE STUDY

The example used to illustrate the technique is taken from a draft

set of provisions prepared for a model performance standard for innovative

structures of residential building. Although no such standard has been

promulgated, previous drafts for the same subject do exist at NBS to serve as a co.mparison for this example. The previous drafts have not

been developed using the outlining technique illustrated here. The form.at

selected for the example provisions is one used for several years at NBS

for performance standards, known as Requirement - Criterion - Evaluation - Commentary or RCEC for short.

This format defines the acceptable kinds of provisions for a performance standard and imposes a hierarchy among them. Performance re- quirements are qualitative statements setting forth desired performance

attributes for particular classes of physical entities. Performance

criteria are more precise statements, frequently containing some measure

of physical behavior, that are used to judge whether a related performance

requirement is satisfied or not. Evaluations prescribe in greatly varying

detail how to measure the quantities called for by a performance criterion.

Commentary is used to explain the rationale and background behind criteria

and evaluation procedures and is optional. The format requires that each

performance requirement have one or more performance criteria and that

each criterion have an evaluation procedure.

The first step in the case study was to establish those classifiers

necessary to organize the set of performance requirements. Table 2 shows

these classifiers and the outline for the requirements. The physical

entities illustrate several important points for use of the method. First,

the scope of the entire set of provisions is limited to the structure of

residential buildings by the title so huilding stands alone at the most

general level of physical entities. Furthermore, there are two subdivisions of buildings that are to be considered: stvuotuval system is

obvious but intevior surfaces are also included because the provisions

will address the structural aspects of interior surfaces. Note that

there are many parallel subdivisions of a building that are not included

(heating system, lighting, etc., which do have structural features) but

that structural system and interior surfaces are a complete expression

of the scope for this set of provisions and thus establish the criterion

for completeness that the organization must meet. Similarly, floors and

walls are not the only possible interior surfaces of a building but others,

such as ceilings, are consciously excluded at this stage because floors

and walls are defined as a complete set. Also note that the terms satisfy

the necessary principle of uniqueness, that is, walls and floors are distinct and unlikely to be confused.

The performance attributes, safety and serviceability , illustrate

the richness in meaning that some classifiers possess. In the context

of design regulations for building structures, safety is generally taken

to mean life safety for occupants and neighbors of buildings. Serviceability ^ however, means more to a wider range of people. For occupants

and neighbors, it means that the behavior of the structure should not

impair the functionality of the building or cause discomfort to the occupants.

For owners, it means that the structure should be maintainable and durable.

Thus, although safety and serviceability are meaningful in the sense that

the intended audience for the provisions understand them, they are not

necessarily simple words.

151
The two environments listed show that arbitrary divisions are sometimes useful for purposes of arrangement as long as they still

satisfy the requisite properties for classifiers. Note that this

division between fovce loads and other agents was not originally perceived but was entered in one of the several iterations necessary to conduct the study.

The outline of classifiers is generated by successively appending

classes together in a hierarchical fashion. The order is arbitrary to some extent, and several different outlines can be generated by using

different orders. Each is equivalent in scope but different in arrangement; that is, each will have a place for each member of a set of provisions but the grouping and ordering will be different. The routine for

generating the outline is simple enough for manual use on outlines of

this size but requires a computer for record keeping on larger examples (3) .

The right-hand column shows that three requirements have been

identified from the outline and designated as Rl, R2 , and R3. The re- lation of the outline to the requirements illustrates several important

points. The first requirement is associated with the three classifiers;

structural system^ safetyj and force toads. Using the rules of syntax

referred to previously (5) , the performance requirement can be expressed

as: "the structural system shall safely support all loads expected

during its service like." The next entrv, an X, shows that a requirement could have been written for the safety of structural systems under

the action of other agents of the environment, but was not. At first

glance this seems incomplete. However, the effect of other agents, such

as heat, moisture, etc., on safety is not direct when compared to force

loads and in fact is coupled to the presence of force loads. Because

the effect of other agents on safety is of a different order, and because

it is coupled to force loads, this effect is covered in the criteria

related to requirement Rl. Decisions about the organization, such as this one on completeness, are not necessarily easy or quick. Complex

physical behavior or arbitrary limits on scope frequently require extended

deliberation and compromise. The outlining technique calls attention to potential missing provisions, such as this, and requires explicit decisions

by the writer.

Requirement R2 is written without considering the distinction

between force loads and other agents. It is not necessary to specify

the environment when writing requirements in many cases, and this is one.

It will be shown that the two classes of environment are useful to group

the criteria for R2 into two progressive sets, so their presence in the

outline will be justified later. The next X shows that no requirement

is associated with the classifiers safety and interior surfaces . This is

because interior surfaces (a wall surface does not include the entire wall) are not considered to present any hazard to life in the structural sense

of their behavior. Other kinds of hazards, such as toxicity, are possible

but are outside the scope of these provisions because only limit states

of a structural nature will be included. Once again, the outline has

identified a potential missing provision and caused the writer to

explicitly consider the impact of leaving it out.

Given that the only phenomena concerning interior surfaces to be

considered by these provisions are those of a structural nature, one is

realistically limited to considering force loads. Other problems of

serviceability , such as paint adherence, are outside the scope, thus,

the last X is shown in the outline.

152
Although the RCEC format specifies that the requirements give the

overall structure, considerable freedom still exists in organizing the

criteria, and the case study will carry on through the development of an outline for the criteria. Table 3 shows the additional classifiers

necessary to organize the criteria. The first and most important class

is the limit states. Each limit state is defined as some event that causes the loss of a performance attribute. In Table 3, each limit

state is shown with the requirement (s) that it applies to, and in the case of those limit states applying to requirement R2, the particular

environment that is relevant. Thus, the limit state failure is associated

with both requirements Rl and R3, and the limit state vibration is associated with requirement R2 when foroe loads are considered.

The remaining classifiers relate to qualities and things used to

further define the limit states and the measures of the limit states.

Each subclass is developed for association with some limit state as shown. Thus, the class drift loads is developed for the limit state

drifts the class load OQOurrence xs developed for the limit state failure,

the class defteotion duration is developed for the classifier flexible

which is part of a class that is developed for the limit state defleotion,

etc

.

In general, these additional classes are necessary to define the

scope in the detail necessary to write precise criteria. Frequently the same distinction can be obtained in alternate ways. For instance, it

is necessary to separate grossly different modes of failure of structural

systems because the performance measures used in the criteria are different.

In this example, the separation was accomplished by considering the different

levels of probability that a given load would occur: 1) those expected to occur once in the life of the structure, 2) those expected to occur many

times in the life of a structure, and 3) those expected to occur in the

life of only a very few structures. It would also be possible to separate

the criteria by having a class of failure types: 1) conventional failure,

2) fatigue failures, and 3) exceptional failures, such as progressive

collapse. The two ways of separating the criteria are nearly identical

in that the same criteria end up being written. The class load occurrence

was selected because it was felt that it was more relevant yet still

meaningful

.

Table 4 shows the outline of classifiers and the corresponding

outline of provisions. The outline of classifiers was generated in

the same fashion as the one for requirements. The provision outline is

simply a condensation of the classifier outline with each heading cor- responding to a requirement or a criterion. Note that in some instances

sub-criteria are necessary to provide the proper hierarchy. The headings

enclosed in parentheses indicate that the subject matter is covered

concisely in one provision corresponding to the preceding heading. They

are shown in Table 4 only to facilitate comparison with the classifier

outline.

Table 5 shows the outline of the previous draft of this set of

provisions compared to the present outline. First, note that the previous

outline is not in the same format. There are 18 headings at the same

level, roughly corresponding to criteria. There is no grouping of these

153
criteria by performance requirement because no requirement is given,

although the heading strength and stiffness is treated somewhat like a performance attribute. Next, note that several of the headings correspond to criterion Cl.l. The evaluation procedure for that criterion

is quite detailed in comparison to the others, and it is some of the

subdivisions of that evaluation procedure that the extra headings in

the old outline correspond to. There are some topics covered in the new provisions that were not in the old; such as resistance to exceptional loads, corrosion, and material property changes. One significant

point to note about the ordering is that the old outline had parts of

the evaluation procedure for new criterion Cl.l separated by relatively

unrelated material, e.g., the provision for capacity of inserts and

hangers is separated from other provisions for load capacity by provisions concerning deflections and drift. Another example of the same point is that provisions for horizontal and vertical deflection of

members are separated by the provision for drift of a building.

CONCLUSION

An innovative method for outlining provisions for standards and

codes is being developed at NBS. This article presents a partial

description of the method illustrating it with one example. A more

detailed description will soon be published by NBS. Although the only

example cited is drawn from a draft performance standard, the method

is equally applicable to prescriptive standards and the full range

between. Application of the method provides explicit checks on com- pleteness and clarity to the writer of the provisions and a more understandable and accessible organization for the reader. It also encourages decisions on scope to be made before studying arrangement, thus

giving an efficient direction to committee deliberations when a new

set of provisions is being formulated.

ACKNOWLEDGEMENT

Special thanks are due Bruce Ellingwood, Patrick Cooke, and George

Turner for their thoughtful readings of the manuscript and Steven Fenves,

Kirk Rankin, and Robert Kapsch for many enlightening discussions with

the authors.

154
REFERENCES

1. Harris, J. R. , "Logical Analysis of Building Code Provisions, "Research

and Innovation in the Building Regulatory Process , NBS Special Publication

A73, National Bureau of Standards, Washington, D.C., June 1977.

2. Fenves, S. J. and Wright, R. N. , "The Representation and Use of Design

Specif ications, "NBS Technical Note 940, National Bureau of Standards,

Washington, D.C., June 1977.

3. Harris, J. R. , Melin, J. W. , Wright, R. N., Tavis, R. L. , and Albarran, C,

"Technology for the Formulation and Expression of Specifications: Volume I,

Final Report; Volume II, Program User's Manual; and Volume III, Technical

Reference Manual." Civil Engineering Studies . SRS No. 423, 424, and 425,

University of Illinois, Urbana, Illinois, December 1975.

4. Pollack, S. L. , Decision Tables Theory and Practice , Wiley, Interscience,

New York, New York, 1971.

5. Fenves, S. J., Rankin, K. , and Tejuja, H. K. , "The Structure of Design

Specifications," NBS Building Science Series 90, National Bureau of

Standards, Washington, D.C., September 1976.

6. "A Classification Framework for the Construction Industry," Directorate

General of Development (Housing and Construction) , Department of the

Environment (United Kingdom), London, England, 1972.

7. Kapsch, R. J., "Existing Architectural Information Indexing Systems,"

NBSIR 76-1064, National Bureau of Standards, Washington, D.C., March 1976.

155
Table 1

Basic Structure of the Classification

THING QUALITY

ENTITY PHYSICAL QUALITY

PHYSICAL ENTITY

HUMAN ENTITY

TAT /^TT ATT rm7 SOCIAL QUALITY

ENERGY

EVENT

PROCESS

ENVIRONMENT

156
Table 2

Classification for Requirements

CLASSIFIERS

Physical Entity

Building

Structural System

Interior Surfaces

Floor

Wall

Performance Attribute

Safety

Serviceability

Environment

Force Loads

Other Agents

OUTLINE OF CORRESPONDING

CLASSIFIERS REQUIREMENTS

Building

Structure

Safety

Force Loads ------ Rl

Other Agents ------ X

Serviceability ------- R2

.Force Loads /*

Other Agents / Interior Surfaces

Safety X

Force Loads / Floor / Wall / Other Agents /

Floor / Wall / Serviceability

Force Loads ------ R3

Floor / Wall /

Other Agents ------ X

Floor / Wall /

A / means that the scope of the requirement above will include

this classifier.

157
Table 3

Classifiers for Criteria

CLASSIFIER ASSOCIATED CLASSIFIER (REQUIREMENT)

LIMIT STATE

Failure

Deflection

Drift

Vibration

Dimensional Change

Loss of Material

Material Change

Rl, R3

R2

R2

R2

R2

R2

R2

Force

Force

Force

Other

Other

Other

Loads

Loads

Loads

Agents

Agents

Agents

TIME MEASURES

Load Occurrence

Expected Maximum

Repeated

Exceptional

Vibration Duration

Transient

Steady State

Deflection Duration

Short Term

Long Term

Failure

Vibration

Flexible (Deflection)

RESPONSE MEASURES

Deflection Compatibility

Flexible

Brittle

Transient Vibration Measure

Amplitude

Damping

Steady State Vibration Measure

Acceleration

Resonance

Deflection

Transient (Vibration)

Steady State (Vibration)

ENVIRONMENT

Drift Loads

Wind

Earthquake

Drift

PHYSICAL ENTITY

Structural Parts

Member

Joint

Dimensional Change

158
Table 4

Outlines

CLASSIFIER OUTLINE PROVISION OUTLINE

Build ing

Structure

Safety

Force Loads

Failure

Expected Maximum

Repeated

Exceptional

Serviceability

Force Loads

Deflection

Flexible

Short Term

Long Term

Brittle

Drift

Wind

Earthquake

Vibration

Transient

Amplitude

Damping

Steady State

Acceleration

Resonance

Other Agents

Dimensional Changes

Members

Joints

Loss of Material

Material Changes

Interior Surfaces

Serviceability

Force Load

Failure

Floor

Wall

Rl Structural Safety

Cl.l Resistance to Max. Load

CI. 2 Resistance to Rep. Load

CI. 3 Resistance to Excep. Load

R2 Structural Serviceability

C2.1 Deflections Under Load

(Short Term)

(Long Term)

(Brittle Materials)

C2.2 Lateral Drift

(Wind)

(Earthquake)

C2.3 Vibration

2.3.1

2.3.2

2.3.3

C2.4

2.4.1

2.4.2

2.4.3

2.4.4

Trans. Vib. Amplitude

Trans. Vib. Damping

Steady State Vib.

(Acceleration)

(Resonance)

Service Environment

Dim. Changes in memb.

Joints

Corrosion

Material Changes

R3 Serviceability of Floors and Walls

C3.1

C3.2

Floors

Walls

159
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160
CONSENSUS STANDARDS FORMULATION

by

Joseph V. Tyrrell

Naval Facilities Engineering Command

Alexandria, Virginia

The charge has been made that the existence of standards

inhibits innovation and consequently hampers technological advances.

On the other hand, standards provide obvious benefits in consumer protection and economics through aggregation of markets. One

possible remedy that has been advanced is provisions for accepting

nonconforming products by exception. While such procedures would

make introduction of new products easier, it would to a large extent

destroy the fundamental purpose of a standard.

Another proposed remedy is to base all standards on performance

requirements. While performance standards may be satisfactory in some cases, they are not a panacea that will easily solve all

standards problems. Adequate definition of performance requirements

and equally important acceptance requirements is a major problem.

The pure performance standard opens the doors to unwanted features

if it is not very carefully constructed.

The concept of standards is not wholly compatible with

innovation, but standards provide sufficient benefit to warrant

continued use. Their effectiveness depends upon procedures for

formulation to make their purpose clear and identify their

limitations

.

Key Words: Economics; formulation; innovation; market

aggregation; performance requirements; prescriptive

standards; standards development.

161
CONSENSUS STANDARDS FORMULATION

The charge has been made that the use of standards inhibits

innovation and consequently retards technological progress. On the

other hand, standards provide obvious benefits in consumer protection and economy through aggregation of markets. By referring

to a suitable standard, architects and engineers can save a great

deal of effort in writing specifications. The intent of this paper

is to examine this apparent dilemma and possibly provide some insight to considerations which should underlie procedures for

foundation of standards.

Before attempting to establish requirements or procedures for

standards formulation, it is necessary to obtain agreement on their

function. Specifically, we must consider the questions, of when

standards are appropriate and how they are to be used.

A common misconception of standards is that they certify that

the requirements have been thoroughly evaluated from the standpoint

of useful services. In fact, many standards are nothing more than

an agreed-upon description of characteristics of an item.

Therefore, standards, as they are now developed, cannot be used in

lieu of engineering expertise. They only afford protection to the user who. is technically competent. In considering standards

formulation, it is necessary to resolve the responsibility of

standards-writing groups to assure that an item covered by a standard will be satisfactory. There is no way for a standard to

prevent misuse of a product and to this extent it is not feasible

for a standards group to provide such assurance. On the other hand,

it seems reasonable that a standard not be adopted if the product is

unlikely to satisfy an obvious intended use. Between these two

extremes is an area that requires careful definition.

Another misconception is that standards groups verify that

items purporting to meet a standard actually do possess the proper

characteristics. This would require a large investigation and

testing effort and involve considerable expense which would

ultimately be borne by the user. Is the additional protection which

might be afforded the public worth the potential cost? Since

standards cover everything from raw materials to complicated

equipment, it may be possible that a single approach to standards

formulation is not satisfactory for all categories of goods. A key

element is the nature of the user and his ability to understand and

interpret the function of the standard.

Standards are useful for widely used items for which there is a large market and a number of potential suppliers. If the item is

not widely used and the potential market is small, a standard is not

warranted. Standards serve two primary purposes. They permit

specifiers to agree on a well-thought-out description of

commonly-used articles. Thus, it is not necessary for each

architect or engineer to constantly reinvent the wheel. Secondly,

they permit suppliers to concentrate on products that will be widely

accepted.

162
Economics possible through standardization have long been

appreciated by American business. Lower production costs usually

result from large volume and economics of scale due to market aggregation are a secondary benefit. Unfortunately, standardization

always limits change and thus inhibits innovation. In a time when

technology is changing at a very rapid pace, it is fitting that

there is concern that standards will retard the utilization of

beneficial developments. The formulation of standards should

attempt to ameliorate this conflict to the extent possible.

One suggestion to make standards more responsive to innovation

is to provide for acceptance of non- conforming items. The question

is who would be responsible for acceptance. The function of

evaluating nonconforming products and determining equivalency is

very different from writing a standard for a well-known item.

Standards writing groups would have to be reconstituted and resources to investigate provided. In addition to serving the

purpose covered by the standard, non-conforming items may have

additional characteristics which might be significant to the user. Only the user could determine the acceptability, for his purposes,

of non-conforming items. Since the user must necessarily evaluate

innovative products, it is difficult to see what service their

inclusion under a standard would provide. The unwary standard user would be liable to experience difficulties in the form of unwanted

surprises

.

Establishing the scope of a standard to include all reasonably

suitable products and still satisfy user desire for specificity is

not easily accomplished. For example, there is an ASTM standard for

plastic pipe. This is a relatively new product that is just

becoming familiar to users. The present standard covers solid wall

pipe which is the type for which there is user experience. Now it

is proposed to include cellular pipe. This product apparently meets

all the requirements stipulated in the standard but has no track

record. Should it be included in the standard now or perhaps later?

Should a new standard be developed for cellular plastic pipe?

Questions of this nature are vital to the formulation of useful

standards

.

The second widely advocated aid to innovations is reliance on performance requirements rather than prescribed characteristics.

The apparent simplicity of this idea is certainly appealing. In

practice it is by no means easy to construct a performance

specification which will prove satisfactory to the buyer and seller.

It can sometimes be done but there are many pitfalls.

Prescriptive standards can deal adequately with well-known

items. The products available on the market are familiar to users. Such characteristics as size, shape, weight, durability, and

maintainability, are common knowledge although they may not be

covered by the standard. A performance standard is essentially a black box approach. All essential characteristics must be covered

in the description of performance or the user will be uncertain that

the item will be.

163
An individual user may have difficulty determining all

characteristics which are really important to him. A standards

group will have additional difficulty because some requirements may

be relevant to one user and not to another. There may be a tendency

to incorporate only common requirements in the standard and thus

leave many loose ends to be picked up by the individual specifier.

This means that performance standards are likely to be more complex

to construct and require greater digression in use.

In writing performance standards there may be a tendency to

focus on the primary function and thereby inadvertently omit other

characteristics important to many users. For example, a check valve

is intended to prevent flow in the wrong direction. However, a performance standard limited to this function might prove

unsatisfactory. Parts that are subject to excessive wear are obviously undesirable as is a housing that is easily damaged. Thus

durability and handling characteristics must be included in the

performance requirements. Some users might consider that

maintainability should be included. Nobody wants a valve that would

require such expensive tools to install, but that could easily be

the result under a performance standard that is not very carefully

drawn. Of course, it is not impossible to devise an adequate

performance standard but certainly involves complexities not found

in prescriptive standards.

It may be concluded that standardization and innovation are not

wholly compatible goals. Standards have proven extremely useful to

the specifer and must continue to be available. The task of making

standards formulation procedures facilitate innovation is formidable

and should be approached cautiously, and with the user in mind. The

existing standards writing groups have proven to be viable because

they fill a need. Some basic regulation may be appropriate in the

public interest, but attempts to permit innovation by requiring set

procedures and a specific format could be counter-productive. It

would be most helpful to users, if a standard contained a brief

statement as to how it was formulated and how it is intended to be

used.

164
THE ROLE OF FIRE PREVENTION AND CONTROL ON

BUILDING CONSTRUCTION AND REGULATIONS

by

William H. McLain

Institute Scientist

Southwest Research Institute

San Antonio, Texas

Fire prevention and control is an important feature of the modern building

codes. Building set-back limits, structural design, and limitations on interior

finish materials are among the building design parameters that reflect the public

need for fire safety. Historically, codes have been developed to reduce mass

urban fires and to limit property damage from the structural collapse of single

building units. For example, a standard time-temperature curve has been developed

and widely used (ASTM E119) for classification of building structural components

in terms of a fire-time rating. More recently, there has developed an increased concern about life safety. Smoke and toxic gas produced by materials subjected

to fire exposures are being evaluated and in some cases form part of a developing

set of new regulations. The implementation of these new regulations poses a number of difficult problems to the local code regulatory and enforcement officials. An analysis is made of some of the alternative approaches which may be

considered to aid the local building official in this important area of control.

Key Words: Building codes; control measures; fire codes; fire safety;

governmental actions; life safety; regulation; risk assessment;

societal goals.

165
INTRODUCTION

Fires have threatened life safety and inflicted losses to property

throughout history. In the past, as now, governmental bodies have responded

to these threats by developing fire service capabilities and restrictive

building codes. Using these solutions effective governmental action has

been implemented for many centuries.

In 80 B.C. Marcus Crassus organized a private fire brigade to protect

his buildings in ancient Rome. These brigades were highly efficient and

during his time fire losses were low. For political reasons after his death

these brigades were disbanded and in 64 A.D. a major fire consumed Rome.

At that time Rome had many of the general characteristics of a modern city

being constructed of 6 to 7 story tenement buildings.

It is instructive to read the historian Tacitus' description of the

rebuilt city a few years later:

"... with rows of streets according to measurement, with broad throughfares

with a restriction in heights of houses with open spaces, and the further

addition of colonades, as a protection to the blocks of tenaments... The

buildings themselves, to a certain height, were to be solidly constructed,

without wooden beams, of stone, that material being impervious to fire, and

to provide that the water which individuals... had appropriated might flow

in greater abundance for the public use,... and everyone was to have in the

open courtyard before their house equipment for stopping fires. Every building

too, was to be enclosed by its own private wall, not one shared with others...".

Clearly the basic elements of a prescriptive city fire code were used.

The elements consisted of fire resistive construction, set back limits, and

material specifications. These elements were supported by an active and ready

voluntary fire service. It is doubtful that the modern city administrator could

improve much on the rebuilding of that ancient city.

Three key elements were involved in this process: (1) technical knowledge,

(2) a public awareness of risk and its willingness to commit resources to

minimize this risk, and (3) an effective governmental administration and enforcement policy. In time, as public awareness dimmed and governmental administration

became ineffective, Rome again became the site of major urban fires. This

cyclical process of major catastrophes followed by rebuilding and decay continued

to the present century. Examples include the London fire in 1600, the New York

fire of 1834, the San Francisco fire of 1858, the Chicago fire of 1888 and the

Boston fire of 1906.

The fact that the incidence of major urban conflagrations has declined in

recent times is most probably due to a combination of increased public awareness

about fire (as a result of modern communication and educational systems) and,

the development of new forms of governmental and private regulatory institutions.

166
Commencing in the latter part of the last century factory mutual insurance

organizations were formed as a protective measure by factory owners to spread

the adverse effects of an individual fire catastrophe over a wider financial

base. A major output of the activities of these mutual organizations was the

development of technical performance codes based on a "concensus" of technical

experts. These efforts have developed into our present system of uniquely

American consensus standards and codes. Effective administration of these codes

was enforced by economic incentives, principally reduced insurance premiums, in

the private sector as well as governmental regulations directed toward general

public safety. In part because of the interests of the insurance agencies, the

primary emphasis of these codes has been directed toward reducing property losses.

Lesser emphasis has been placed on life safety.

For a number of reasons during the past decade there has been an increasing

public awareness of hazards to life safety resulting from unwanted fires, particularly in one and two-family dwellings. Since legal responsibility for fire

deaths in these occupancies has not resulted in monetary losses to the fire

insurance underwriter, incentives which have effectively reduced property damage

losses are not fully operative. Because of these factors there is an increasing

political demand placed on public officials to develop and enforce fire codes and

standards in which primary goals will be to reduce the number of home fire deaths.

This is both a local and community and national problem area for governments.

To perform this service it is apparent that new concepts and approaches must be

developed which can complement our present system of concensus codes. One of

the new approaches to this problem is the investigation of codes which is based

on the level of risk the public is willing to accept in terms of the fire hazard.

LEVEL-OF-RISK FIRE CODES

The acceptable risk associated with a specific hazard varies both with

respect to the type of hazard, and, the local community standards. Thus, a much

higher factor of risk is generally acceptable for loss of life in a single family

dwelling unit as compared to loss of life in an airplane crash. Similarly, arson

is common in many urban ghetto areas and rare in most suburban neighborhoods.

One of the implications of a variable acceptable risk is that for the same

hazard, (e.g. loss of life in a domestic fire) there may be different political

pressures on government for control and regulations. These demands reflect the

relative order of priorities of a specific community. In the United States the

major underlying philosophy of the Fire Prevention and Control Act of 1974 is

that control of hazards associated with fire is a problem of local government.

State and local officials are expected to make their own decisions on the level of

safety they want and determine how much cost is reasonable. However, it is

impractical for each local political subdivision to perform the necessary research,

development, and evaluation to produce its o\m individualized fire safety code.

This poses a dilemma.

The current solution to this dilemma is for the local community to adopt

one or more of the major model codes. At present there are at least 10 major

model codes directed toward regulative fire safety in buildings and hundreds of

167
voluntary technical standards. A major problem is that State and local officials

lack an objective basis for comparing these model codes in terms of the safety

provided and costs incurred.

One way to resolve this problem is to develop a single national concensus

code. Either the prescriptive or performance codes could be utilized for this

purpose. One major advantage of this approach would be a reduction of the problems incurred by manufacturers to produce and market on a national basis.

Although a universal national code would reduce conflicts, it also limits the

flexibility of local code groups to formulate requirements best suited to

individual communities.

A second way to resolve the problem is to develop a form of fire code in

which emphasis is given to providing the local official with an objective system

for evaluating alternative solutions in terms of the acceptable levels of risk

in the community but which also utilizes the benefits gained from the concensus standard system. Such a code would include a number of discrete elements. First,

the risk associated with the hazard must be defined for the community. This

requires a statistical data base either for the specific community or for a group

of similar communities. Secondly, the acceptable level of risk must be specified.

This requires a political insight into the sensitivity of the community with

regard to the potential hazard. The sensitivity of the citizens of Southgate,

Kentucky, toward interior finish and existing requirements in restaurants is

currently very high after the recent Beverly Hills Supper Club fire. The code

must be able to accommodate this selective sensitivity. A third desirable element

is flexibility. The code should provide a mechanism where alternate solutions may

be selected in order to have sufficient flexibility to allow new material and

construction practices to be used on a national basis. Finally, to be effective

any code must be administratively enforceable.

A hypothetical example of a level of risk code would be the development of

building code criteria designed fo reduce loss of fire fatalities in one and twofamily dwelling units. Recognizing that individual fires in homes result in an estimated 8000 deaths per year an objective of a building code might be to reduce

these by a "reasonable" number. Although" limited reliable data is available, it

would appear that the room of fire origin in fatal fires may, in many cases, be

in a lower floor area. The reason for this fact is that smoke and heat rise from

these lower areas often resulting in a threat to life safety on the upper floors.

In other cases, the room of fire origin is the same as that in which the fire

fatality occurs (e.g., a bedroom). The room of fire origin for one and two-family

dwelling fatalities are summarized in Figure (1)*. It is noted that these data

are obtained from national statistical averages which may or may not represent

the average for a specific community. Figure (2) lists the compartment level of

risk normalized to an arbitrary basis of 100. Assuming the statistical data is

*Fire Protection Handbook, 14th Edition, p. 1-8

168
valid, the results indicate the areas in which most fatal fires originate

are the basement, living room, and kitchen having values of 53.5, 22.5 and

16.7 LOR"*", respectively.

This information can be used by the code official to determine the relative

risk associated with living in a specific dwelling unit. For example, in

Figure (3), a plan drawing is given for an individual home. Multiplying the

number of rooms of each type in this home by their national average risk value

the level of risk is determined. Without a basement the relative level of risk

is associated with living in this home is 81.1 LOR. With a basement it becomes

134.6 LOR.

The next step in the process involves an assessment of desirable community

goals in terms of the "allowable" level of risk that will be acceptable as a community standard. This assessment is essentially a political judgment. A

possible community standard might be to not allow construction of new homes having

a LOR greater than 75 based on national averages. This level of risk would act

to reduce fire fatalities in the community as compared to a national norm. A

second approach would be to establish a community-specific data base and use this

base to provide similar guidance.

In order to m.ore closely define the problem it is useful to determine the

level of risk for individual compartment. Again since the data presented in

Figure (1) is relative to a national statistical base for fires in one and twofamily occupancy classes, the level of risk associated with individual areas of

the home can be estimated from U.S. Census Bureau data. Once a community standard

has been selected (e.g. 75 LOR) the code official can thus discuss with the builder

various building options. Some of these options are listed in Figure (4), together

with an itemization of other technical input that may be required to evaluate each

option. Since the goal is to reduce the level of risk, judgment must be exercised

regarding the effectiveness of each option when installed in the specific building.

In this case, an efficiency of 100 percent effectiveness was assumed. In a practical code decision reference would be made to technical consensus values.

Possible results for three contractor options are outlined in Figure (5) . Installation of a sprinkler in the living room or area would reduce the LOR value to 55.6

for a non basement house. In this case, a possible alternative of the installation

of a sprinkler in the den would not be acceptable since the den is not in direct

communication to the stairwell leading to the second floor level. Similarly,

installation of a fire detector in the stairwell would provide protection from most

fires starting in the lower floor area. In this example, no substantial protection

would be required for the den area and the additional placement of additional

detectors in every bedroom occupied by a person who smokes would be recommended.

As indicated previously, one of the problems associated with this approach is

the determination of the relative effectiveness of alternate fire suppression/fire

warning systems. Before level of risk codes can be developed, much more technical

The unit LOR is defined as the level of risk associated with an average occupancy

class relative to the assumed hazard.

169
information in this area will be needed. One point of concern is the fire control

effectiveness of low rate of application water sprinklers. A second problem area involves the judgmental factors associated with "type of occupants" assumptions.

For example, if non -ambulatory occupants are present the use of smoke or heat

detectors may be less satisfactory than sprinklers. Because of the range of

technical sophistication that is needed to effectively solve these problems it

is probable that some form of consensus group opinion may be required from technical

experts in the field. However, it is believed that these problem.s are amenable

to reasonable solutions.

The principle advantages of a level-of-risk type code outlined in the above

example are: (1) specific solutions may be formulated for individual communities

and buildings, (2) these solutions can be highly flexible in providing alternate

solutions and alternate goals, and (3) cost effectiveness to achieve a prescribed

level of risk. The major disadvantages are (1) a need for a community specific

data base, and (2) a need to define community goals. It will be interesting to see how regulatory building codes in the future utilize these more formalized

acceptable risk principles at national and local levels of government.

170
SUMMARY

The development and use of fire codes cannot be separated from other

available community services such as fire suppression and public education.

All are necessary components on a community program for fire safety. An

effective fire code reduces the personnel and equipment requirements for

fire service. An effective program of public fire education similarly is

important to an effective fire code.

It is necessary to realize that fire codes are not simply a set of

technical requirements. Rather, they involve a combination of technical,

political, and administrative balances. ^^Jhat is important is that the

general community believes that there is a clear and present danger and

that the control measures taken are reasonable (i.e. cost effective,

technically valid, and closely related to current community practices).

Technically, we have had the knowledge of how to implement an effective building code for at least two thousand years. Historically,

this knowledge has been effectively used only periodically. Given a crisis

caused by a major fire catastrophe, political and administration institutions

are developed and implemented to reduce the probability of crisis reoccurrance.

These rely on available technology for specific control measures and the

absolute level of risk is less relevant than the visibility of the hazard. As

the public awareness of the hazard recedes the enforcement becomes lax and a new cycle begins.

Building codes related to community fire safety are in a state of change.

These changes reflect changing societal goals. In the recent past (i.e. the

past 50 to 75 years) a major societal goal was to reduce mass conflagration in

major urban areas. Our current building codes reflect these concerns. Recently

there has been more emphasis on life safety. It is anticipated that more measures

to reduce fire hazards which affect individual life safety will be incorporated

into our building codes in the future.

Compared to our national net worth our losses are relatively low and the

probability of a major urban conflagration is low. The major question is,

"How can we do better with the political framework of our democratic nation?"

particularly with regard to improving individual life safety in home fires.

One answer to this question is a level-of-rlsk assessment. This new type of

code provides a variety of technical solutions which can be adapted to the

specific needs of individual local communities. In these codes the level-ofrisk is estimated for alternate materials, equipment, and construction practices

and then related to community priorities for specific occupancies. This new

approach to the code regulatory problem provides a combination of technical,

political, and administrative balances uniquely suited to the American form of

democratic institutions.

i

171
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176
BUILDING REGULATION IN THE TWENTY-FIRST CENTURY

by

Hans J. Milton, FRAIA, Assistant Secretary

Australian Department of Environment,

Housing and Community Development

Currently a Technical Consultant at NBS/CBT

on Metrication and Dimensional Coordination

Many research papers have been devoted to proposals dealing wi

innovation and rationalization in the building regulatory process.

This paper has two special features—it takes a broad and

uninhibited look at the entire field of building controls, and it

does so from an imaginary future date in September 2002, a quarter

of a century after the Bozeman, Montana, conference. Instead of

proposing changes, the paper takes a novel approach and discusses

"retrospectively" the major changes that "have occurred" in the

intervening 25 years. It thus provides food for thought without

running into the gamut of reasons why changes cannot be made.

Key Words: Building regulations; innovation; international

standards; metrication; performance standards;

research; technological trends.

177
INTRODUCTION

The theme of this conference is "Research and Innovation in the

Building Regulatory Process." This is a serious, appealing, and

recurring theme. In my view, a luncheon speech should be related to

that theme; however, it should relieve the seriousness of the

technical sessions without sacrificing too much substance.

Any views expressed in this presentation are entirely my own and

have not been censored by anyone. The ideas proposed have been

developed as a result of many discussions with people knowledgeable on

the subject of building control; the hypotheses are my own; and any

mistakes made by me in the description of existing or former

activities or organizations are also my own. In projecting the title

of my presentation, I am guided by the realization that the

twenty-first century, and the start of the second millennium are less

than 23 years away. This point in time serves well to direct our thoughts to the future and to the need to formulate a series of

objectives and related achievement targets for beneficial change.

Research and innovation are major arms of that "change."

Research is the intellectual activity that projects proposals from the

study and analysis of historical factors and trends. Innovation is

the profound human capability to simplify, modify, improve, and

originate within a reference framework of future expectations. While

change is not always for the better, the pursuit of it is a keystone

of human activity. It is probably the factor that sets the human

being apart from other forms of life which have been content to remain

in a static state. In recent times, change has become so rapid that

the results have been demanding, distressing, and sometimes

demoralizing for many people. My prognosis for the next quarter of a century is not promising - changes will continue to occur at a rapid

rate and some people will withdraw rather than endeavor to keep pace.

But, if change were to be harnessed by objectives to give it

direction, we might cope more easily.

In building, and especially in the building regulatory process,

many changes are proposed and pursued. If we gaze into the crystal

ball we get an indication of additional changes. But it is for us to

harness any such changes to the benefit of the community at-large, and

to set markers in the channel of progress so that we can stay on course

In postulating a "view of the past" from the year 2002, I am guided by a number of factors and trends. It would have been

improbable in 1952, just 25 years or one generation ago, to predict

the technological evolution and trends of today - but not impossible.

In "looking back" at events, we can compare their consequences with

the expectations that we now hold and we may learn a great deal from

such a comparison. One advantage of this approach is that any

tendency to say "you should do" or "you should have done" is tempered

to a much more palatable "you might do" or "you might have done." The

proposed process is one of innovation, demanding a good deal of

imagination and inventive ability.

178
TWENTY-FIVE YEARS FROM 1952 TO 1977

In order to put a perspective to my remarks I wish to go back to

the Olympic year 1952. I have brought along a facsimile of pages one

and two of the New York Times of 20 September 1952, to remind us of some of the events of 25 years ago. At that time it sold for five

cents

.

The year of 1952 was the time of escalation in the Korean

conflict and of the presidential campaign of General Dwight D. Eisenhower. Even Richard Nixon made page one of the Times . It was before the advent of the transatlantic telephone cable, the use of

transistors in communications and calculating devices,

transcontinental jet travel (the commercial jet aircraft had not

arrived), and large-scale data processing activities. Copying of data

was slow and cumbersome; the XEROX machine was yet to be developed.

Satellites and manned missions into space were still science fiction,

as was the heart transplant.

In the generation since 1952, technology has advanced at an incredible pace, so much so that our time has become known as the

"space age" or the "information age."

If we ask whether construction has moved equally fast, the answer

is no. We have higher buildings, faster lifts, and more imaginative

structures, but today's buildings are probably not too different from

those of 1952. The advances have been in mechanical systems and

services, which require a vast increase in energy supply to provide

heating, cooling, air conditioning, and power for innumerable

appliances - thus increasing our energy dependence.

Nowadays we are highly dependent upon the comfort we have

created. We have shaped our buildings and they, in turn, have shaped

us. In general building, the cost of the mechanical component has

increased, as innovation in that area has excelled.

One significant building innovation in the past 25 years has been

the mobile home; and only time will tell how permanent that innovation

will be. I have been told that the mobile home has been a direct

outcome of a loophole in statutory requirements, which deal

differently with a habitat on wheels than with one firmly set into the

ground

.

In building codes generally, there has been an accelerating trend

towards statewide requirements as the demands of the infused

technology have required the removal of local barriers to economical

production.

Thus, we have arrived in 1977 with a building scene that has seen

rapid increases in the cost of new construction, as well as in the

market price of pre-owned buildings. Our society has a vast

investment in building assets, and the burden of maintenance and

rehabilitation is growing rapidly. Retrofit to suit special needs

(energy conservation, handicapped occupancies, fire-related

179
requirements, etc.) is expensive and must be borne either individually

or by the community.

To proceed into the twenty-first century, one might well ask some serious questions and do some serious thinking on research and

innovation.

How can we best guide or direct (regulate) both new construction

and rehabilitation?

How can the codes and standards system make a meaningful contribution to the challenges before us? How can it be improved?

Is the fragmentation of activities conducive to innovation, or is

it counter-productive?

To answer these questions, we need to have a sense of purpose

(goals or aims); objectives that are derived from the purpose; and

strategies to achieve such objectives. We might ask: What is the

purpose of the building regulatory process? What is the purpose of

codes and standards? What is the objective of each section or item in

each code and standard? Or what ought it be? Are our requirements and

recommendations clear and concise, or do they represent a semi-technical, semi-legal nightmare? Where do we want to be 5 years

from now, 10 years from now, and 25 years (one generation) from now?

All this is part of the traditional approach.

TWENTY-FIVE YEARS FROM 1977 TO 2002

While the present is seen by many as the extension of the past,

it is also the threshold to the future. And, if we move to a hypothetical date in the future, we will be able to see the present in

the perspective of the past.

I would like you to imagine that you are in the year 2002 - one generation, or 25 years from now. You are seated next to John

Alexander, Coordinator of Codes Development at the National Codes and

Standards Center, who is presiding over a video-link meeting of the

National Committee on Code Reform. The meeting is due to commence in

one-half an hour at 10:00 Central Standard Time. John Alexander is

seated in front of the video-link console which has a triple function:

1. It provides instant access to the meeting by all committee

members and all other interested parties. There is no secrecy; however, only committee members can discuss matters

or present information. Meetings are held and

video-recorded at a single and central point so that much

more productive use is made of time since lengthy travel by

committee members is avoided.

2. It allows for a video-tape transcript of proceedings so that

what used to be minutes are instantly available. This

places a much greater onus on the committee members to

180
properly prepare for the meeting. Any discussion of

irrelevant matters and sidetracking of issues now becomes

widely evident and is recorded. A coupled random access facility provides a video-record of all previous meetings,

so that any reference to previous discussion or decisions

can be factually substantiated. All resolutions are typed

out on the video screen before being voted upon.

3. The video-console is linked to a general data storage

facility of codes and standards information, so that a retrieval and visual display of any relevant technical data

is accessible once the correct access code on the console is

pressed. A secondary display unit is coupled to the

video-console so that data searches may be carried out

concurrently with the meeting. Each console also has a reprographic facility so that video-copies of any particular

aspect can be made for closer examination.

Let us ask John Alexander to demonstrate the facility. We wish

to compare existing requirements for site controls and fire protection

(exit requirements) for data processing centers in various regions of

the U. S., to ascertain whether there are any differences of a technical nature, and what their economic impact might be. The areas

of interest are the Missouri basin (Missouri, Kansas, Nebraska, Iowa),

the greater Washington, D. C. Metropolitan area (D. C. , Maryland,

Northern Virginia), and the Cincinnati region (Ohio, Northern

Kentucky, Southeastern Indiana).

John Alexander selects various data codes from a coding index in

front of him (building type, site control requirements, fire

protection exit requirements). He then presses the code for Federated

Model Code (FMC) , as well as the code for each condition and each

alternative location. (FMC is the Model Code prepared by the American

National Model Codes Council.) As each set of requirements is shown on the video-screen, he activates the copy button to obtain a reprographic copy. It takes three minutes to assemble an up-to-date

data file for ten localities. Where requirements are identical with

the FMC, the printout simply states location, requirements, and FMC.

Similarly, any reference standards can be accessed and reproduced

instantly.

This data now can be used for decisions by the building client,

the building designer, the building materials' producer, the building

contractor, and the building official.

The information age has arrived in codes and standards, but it

would not have been possible without the developments of the past 25

years.

Let us ask John Alexander to give us his views of some of the

significant developments during the past 25 years in the time

remaining before his meeting.

181
THE PERIOD FROM 1977 TO 1982

The first phase in development of the present state of building

regulatory and standards practice occurred between 1977 and 1982. The

highlights of that phase were in the development of programs leading

to the adoption and administration of uniform comprehensive building

codes and standards.

A. Greater Interest and Involvement in the Unification of Building

Regulatory Requirements by State Governments

In the late 1970' s, pressure increased from a number of sources for a review in the processes used to develop and

implement building standards, building codes, and building

regulations

1. Industry, in general, expressed forceful views that the

existing system of standards and building codes development

was economically disadvantageous to the community. In a well documented campaign in which it was joined by

professional and contractors' associations, it demonstrated

that the same building processes and building elements were

subject to as many as twenty differing requirements in

various States, major cities, and localities.

Recommendations were made to the National Institute of

Building Sciences (NIBS), which had become operative in

1978, to set up a technical evaluation branch to recommend means of simplification and unification of criteria,

standards, and technical provisions used by building

regulatory jurisdictions and agencies, and to establish

uniform test methods and evaluation techniques for building

systems and products.

2. The Plastics Industry brought a constitutional challenge

against several State governments and local government

authorities, as well as two model codes, on the grounds of

inhibition of interstate trade and commerce imposed by

requirements restricting the application of plastics in

building situations. The case was left in suspension, but a strong groundswell against arbitrary rejection of materials

was evident.

3. The Federal sector, through authorizations by Congress and

under powers given to various agencies, increased its

efforts to establish national requirements in the building

regulatory scene. Federal thrusts developed in the early

1970' s in relation to mobile home requirements and

considerations for the handicapped were followed by programs

aimed at the development of uniform requirements for:

a. Fire safety in buildings (fire protection, detection,

and prevention)

182
b. Energy requirements for public and private buildings

energy conservation related design

application of alternative energy sources (solar,

waste energy regeneiration)

energy efficient ret.rofit

c. High hazard environments

earthquake protective design

high wind design and retrofit

flood control design and retrofit

d. Special occupancy requirements

handicapped, sick, and infirm building occupants

elderly building users

buildings with a high percentage of child

occupants (nurseries, schools, etc.)

The role of the National Confei'ence of States on Building

Codes and Standards (NCSBCS), expanded considerably when it

entered into a contract with NIBS to set guidelines for the

harmonization of regulatory processes, practices, and training of

regulatory officials.

The NIBS Performance Codes and Standards Task Force

In the late 1970' s, it became e\^ident that problems in the

building standards, codes, and regulat.ions field were not so much

"technical problems" as "resource allocation problems." To

obtain a new basis for all definitive material relating to the

building regulation process, the National Institute of Building

Sciences (NIBS) , formed a high-level full-time Performance

Codes and Standards Task Force (PCSTF) , to develop and promulgate

nationally-recognized performance crit.eria, standards, and other

provisions for the maintenance of life, safety, health, and

public welfare suitable for nationwide adoption. The performance

approach was selected over traditional prescriptive approaches to

allow the widest practicable latitude for innovation in design

and production, and cost stabilization due to the forces in a competitive marketplace. The Task Force developed a system of

Objective Levels to define performance requirements and means of

verification. These were as follows:

Level 1: Fundamental Objectives : setting out the "basic"

principles in relation to any building complex or system, as well as the basis of a structured approach.

183
Level 2: Derived or Wide-Rangiiig Objectives : setting out the

purpose of each major division of activity or subsystem

in the form of objective statements delineating the

functional performance expectations for various

elements or service networks under specified

environmental or othe?r service conditions.

Level 3: Specific Objectives : setting out, in detail, the

requirements (functions or properties) of specific

building items, such as assemblies, components, or materials, as well as criteria for their installation

and maintenance.

Specific objectives, to a large extent, are dependent

upon the framework set down in Level 2. Since

alternative solutions can be described in terms of

their compliance, this level also comes closest to the

traditional prescription approach.

Level 4: Objective Match : set^ting out uniform requirements for

acceptable test me1:hods and procedures to verify

objectives fit. This Level also is complemented by a scheme of compliance certification.

Prior to the establishraont of the Task Force, much of the

effort was devoted to work at Levels 3 and 4, without the benefit

of an overall objective system. The Task Force quickly dispelled

doubts as to the validity of: its work by using the "objective

system" to test existing model codes and building standards.

Many clauses in these documeints had extremely obscure purposes,

and in some cases no reasons could be advanced as to why they were included at all. It was recommended that in any codes and

standards review, an objective statement be provided for each

clause (showing the "why" or reason for the clause) to justify

its inclusion.

The objective system v/as widely accepted and led to a general review of technical statements in codes and standards.

The United States Joins the Metric Building World

Conjointly with these developments, a great challenge to the

building regulations and standards community occurred in the

late Seventies and early-Ei.ghties when the U. S. finally moved to

become a metric community. National voluntary standards bodies,

which had lost considerable international sales of publications

when Canada, Australia, Britain, and 41 other predominantly

English-speaking countries turned away from their customary

measurement systems, had realized early on that metrication was more than just a nuisance requiring reprinting of documents in new units, dual stocking, and obsolescence of part of the

standards inventory. They saw that it provided a unique

opportunity for review and rationalization, for the elimination

of duplication, for a nationwide updating of standards reference

184
facilities, and for a reemergence of American technological

"know-how" on the international scene.

Frantic activity ensued on all fronts to develop and issue

rationalized metric building standards. Considerable support

came from the Federal Government as directives had been issued

that metric standards from voluntary national standards bodies

should be adopted wherever available, and a metric standards

development program was subsidized equally by the Government and

industry.

Metrication in the model building codes area had an even greater impact. It further reduced the differences between

technical requirements expressed in different codes. The Model

Codes Standardization Council established a Coordinating

Committee on Metric Construction Codes (CCMCC) . This Committee

was given a set of objectives similar to those espoused by the

former Joint Committee on Building Codes. However, it added a general objective to preserve and establish a harmony of

numerical values in metric model codes through the use of

standardized procedures for conversion, rounding, and

rationalization of values. At the same time, it was decided to

introduce uniform fire-related requirements to head off a challenge from a proposed Federal Fire Code for Buildings.

At the legislative and enforcement levels, more States moved

towards statewide uniform metric building and building service

requirements. This was the result of two factors. Firstly,

there were approaches from industry for uniform regional and

statewide implementation dates for metric building regulations.

Secondly, there were requests for statewide requirements by local

authorities who were daunted by the prospect of having to

"convert" individual building requirements and then to train

people without the benefit of well-developed documents.

The metric conversion efforts continued well into the 1980 's and provided a significant demonstration of the ability of the

codes and standards community to achieve common objectives and to

cooperate in harmony. The new communication channels developed

as a result of metrication provided a most useful basis for

subsequent cooperative efforts.

THE PERIOD FROM 1983 TO 1987

A Standard Format for Building Information

As an extension of the objective system developed by the

Performance Codes and Standards Task Force (PCSTF) , work

commenced on the development and introduction of a "standard

format" and general classification system for all building

related data. This system would allow for an orderly structure

of technical information in building regulations, building

185
standards, test data, compliance certificates, technical

instruction, specifications, and technical reference literature.

It quickly became apparent that the information and control

process could be greatly simplified by a systematic approach to

the presentation of information especially an approach that was designed to suit a data processing environment.

To simplify application, legal and administrative

requirements dealing with purpose, scope, application,

enforcement, appeal, and review were separated from technical

requirements.

Many formats were examined for the presentation of technical

requirements, but ultimately a system reflecting the concept of

levels was introduced. Firstly, building codes were separated

into four activity categories:

1. demolition and site preparation for new construction;

2. building design and construction, including all services;

3. building operations and maintenance; and,

4. building rehabilitation, renovation and retrofit.

For the new building design and construction code, the

largest single activity category, the following technical

subdivision was adopted:

a. Basic performance design for buildings and services systems:

relating to local factors (siting requirements, fire

zone, flood zone)

relating to different environmental factors (seismic

zone, wind zone, snow zone, thermal zone)

relating to building occupancies and their operational

and functional needs

b. Derived performance design in relation to:

structural factors

fire safety

accident safety

hygiene and environmental health

functional system performance

energy conservation.

186
c. Performance criteria and standards for building elements,

products, materials, and services systems including fixtures

and appliances; and their installation. The emphasis on mechanical, electrical, plumbing, communications or composite systems is at this level.

d. Test methods and certification requirements.

e. Accreditation, testing, and certification facilities.

The classes of occupancy agreed upon were related in matrix

form to each requirement (clause or item) so that a tick against

any one clause was adequate to show its applicability. Clauses

relating to specific building occupancies (types) were thus

clearly identified

International Activity

As a result of metrication, the United States began to play

a more prominent technical role at the international level. The

U.S. made many proposals for international standards and

technical guidelines through the work of the International

Organization for Standardization (ISO), the United

Nations - Economic Commission for Europe (UN-ECE) project on harmonization of building controls, and other activities.

THE PERIOD FROM 1988 TO 1992

The developmental work on an objective system and general

format had been so successful that it led to the establishment of

a National Construction Codes and Standards Center (NCCSC) . This

center had a number of technical operating divisions, which were jointly financed by industry and Federal/State governments, to

develop, coordinate, and review technical standards under the

broad overview of the National Institute of Building Sciences.

In addition to the divisions, there were four offices in the

Center which dealt with administration, education, legal

interpretations, and communications (including publications).

This Center became the technical focus for many of the

fragmented activities that previously had been carried out under

varying auspices. Its essential purpose was to organize technical

resources in such a way as to avoid duplication. Simultaneously,

innovation in relation to building design and construction,

materials and systems production, and installation procedures

were encouraged by the development of a system of "innovation

permits," for limited application of alternative technology in

building situations. This system was under the monitoring overview

of the National Conference of States on Building Codes and Standards

187
With proper review and monitoring, the innovation permits

provided a "field testing" system to supplement the more traditional laboratory-based testing approaches.

THE PERIOD FROM 1993 TO 1997

The trends of preceding activity had made building codes and

standards far more uniform and easily comparable.

The remaining model code organizations had decided to pool

their resources in a federation of model codes. This was done to

preserve their valuable function of developing inputs into the

building regulatory system in the face of increasing Federal and

State government activity in relation to the unification of

building requirements. This federation was called the American

National Model Codes Council (ANMCC).

The Model Codes Council joined with the National Institute

of Building Sciences (NIBS), the National Conference of States on Building Codes and Standards (NCSBCS) , and the National Bureau of

Standards (NBS) to establish a National Construction Codes Data

Service (NCCDS) in association with the National Construction

Codes and Standards Center. The National Construction Codes Data

Service provided a comprehensive printout and readout service for

any specific set or combination of code requirements. For a fee, an instant search and retrieval system became accessible to list

or compare any local, regional, national, or North American

requirements. Requirements were classified according to building

use, building type, building product or process, or special

requirement (hazardous environments, special occupancies or users, restricted uses, etc.).

By now the turbulent decades since 1977 had settled down

into a system which was streamlined, widely understood, and

utilized to expedite the "software" or paper-based processes in

building activity.

THE PERIOD FROM 1998 TO 2002

At the turn of the century and the millennium,

considerations turned outward. With the building codes and

standards situation now relatively stable, the United States

codes and standards community became involved in technology

exchange programs with other nations. A major effort at both

regional (North American) and international level was aimed at

the harmonization of building requirements and standards, under

the terms of an international "bimillennium project" sponsored by

the United Nations. By the year 2000, the U.S. had returned to

technological leadership in the building and building standards

world.

188
CONCLUDING REMARKS

I have had a lot of fun developing this presentation. For those

of you who regard it as a spoof, please look at it seriously; for

those who regard it too seriously, please think of it, at least in

part, as a spoof.

In this excursion into the future, the present has been shown as the past. What are we to learn from this lighthearted but

nevertheless meaningful speculation?

The significant lesson is that in our increasingly complex

society we cannot afford to drift from event to event if we wish to

protect the aims of the community. We have to apply the human

capacity for research and innovation in an imaginative and

goal-oriented way and as the stepping stone for planning,

coordination, and achievement.

The technical aspects are much easier to resolve than the

political and human problems of giving change a meaningful dimension.

Empires under attack will fight vigorously to preserve the status quo,

before entering into programs intended to promote greater

productivity.

But in order to be successful, we need a set of objectives - objectives that spell out the purpose of our activity, as well as making it possible to measure accomplishments against them.

The major objective of all parties in the construction community

ought to be to devise and implement a simple, harmonious,

intelligible, and easily accessible set of regulations, codes, and

standards within the context of the regulatory system, but not

necessarily demanding uniformity. We ought to set an overriding

objective and that is to create and protect a built environment which

makes it possible for man to function in this complex world . We need

to be aware that as we shape our buildings and structures, so, in

turn, they do shape us. Good buildings are one prerequisite for the

maintenance of a healthy, vigorous, and happy community. Inadequate

buildings, as sociologists tell us, can lead to serious consequences

of distress, despondency, and damaging attrition.

In such an objective, building codes and standards are an important tool. In my view, they ought to form the most important

basic reference in the construction community and in the general

economy. And, they ought to be accepted equally by the paid public

administrator, the technologist, and the businessman.

While it is probable that many of the existing codes and

standards will be superseded or harmonized by the end of this century

and some will disappear entirely, the local code administrator should

not suffer. He or she will work more effectively with a system that

is understood and accepted by all parties; that is more easily

maintained, updated, and verified; and, that facilitates the

educational process. NCSBCS, NIBS, and the model codes will survive

and grow if they are attuned to the future as well as the past.

189
In my opinion, we must be forward looking to benefit future

generations. We need a wide commitment to a set of objectives; the

funding of non-partisan and multi-disciplinary research; enthusiastic

leadership which introduces a sense of direction to our technological

resources and skills; innovation and ingenuity; and, most importantly,

the goodwill of all parties that are affected by new initiatives. The

opportunities for accomplishment in the building regulatory field have never been greater - they just need to be grasped.

190
THE TEXAS APPROACH TO ENERGY CONSERVATION BUILDING STANDARDS

by

Michael N. Hart

Principal

Energy Engineering Associates, Inc.

Austin, Texas

and

Jerold W. Jones William Bowen, P.E.

Associate Professor Project Analyst

University of Texas at Texas State Building

Austin Commission

In 1975 the State of Texas Legislature mandated that energy

conservation standards be developed for new State Buildings. The

legislation called for the development of performance criteria and for

guidelines for energy efficient design for different classes of state

owned or financed buildings. In complying with the requirements of

the law, the State Building Commission sought to minimize any adverse

impact of the new standards on the design process.

The State of Texas Building Energy Conservation Standard is

divided into sections on the envelope, mechanical equipment, lighting^

and service hot water. The standard is similar to ASHRAE 90-75 in the

mechanical equipment and service hot water sections, but differs in

the lighting and envelope sections. The lighting section specifies

watts per square foot for most task areas with foot-candle

designations for unusual areas. The building envelope section

provides a new approach. It assures a minimal thermal performance of

the shell by specifying an Energy Envelope Index which is a function

of building size and location. The EEI calculations are similar to

standard procedures for estimating loads (such as those published by

ASHRAE) and is presented in the State Energy Conservation Manual.

These procedures are summarized in this paper.

It is felt that the State of Texas procedure, while innovative,

provides a flexible and workable standard acceptable to both the State

and the design professionals and introduces a new approach toward

performance standards.

Key Words: Alternatives; ASHRAE 90-75; building standards; energy

conservation; performance standards.

191

i
INTRODUCTION

In 1975, the 64th Texas Legislature enacted the Energy

Conservation in Buildings Act. The purpose of the Act was:

to provide for the development of improved design, lighting,

insulation, and architectural standards to promote efficient

energy use in State buildings including buildings of

state-supported institutions of higher education, to reduce

wasteful or uneconomic consumption of energy by balancing the

cost of energy procurement against the cost of energy conserving

building practices to achieve the minimum lifetime cost for all new State buildings, including new buildings of state-supported

institutions of higher education, measured by combined

construction and operating costs, and to provide information to

the public relating to energy saving uses, designs, construction

methods, and techniques for all new and existing buildings.

The Act required the following three specific items to be

accomplished by the State Building Commission and the Governor's

Energy Advisory Council to fulfill the purposes outlined in the law:

1. Energy Conservation Design Standards for all new State buildings.

2. Technical assistance to cities in the form of model energy

conservation building codes.

3. Energy conservation manual for potential use by designers,

builders, and contractors of residential and nonresidential

buildings.

The staff of SBC and GEAC chose to enlist the aid and advice of

an advisory committee selected from the professional design community

and construction industry in the development and review of the

standards for state buildings and the model codes for the cities. The

staff and the majority of the model code advisory committee felt that

the most efficacious solution to the model code requirement would be

to use the draft of the NCSBCS model code as a basis and submit any

necessary changes to NCSBCS and the national model code groups for

consideration.

The staff was constrained by requirements to the Act to produce

standards for state buildings that would:

include both performance and procedural standards for maximum

energy conservation allowed by the latest and most effective

technology consistent with the requirement of public health and

safety regulations and economic considerations.

Subdivision 35 of Article 1175, Revised Civil Statutes of

Texas, 1925.

192
The standards shall be promulgated in terms of energy

consumption allotments and shall take into consideration the

various classes of building uses. Performance standards shall

allow for design flexibility since only the total allotment of

energy is prescribed.

Procedural standards shall be directed toward specific

design and building practices that produce good thermal

resistance and low air leakage and toward requiring practices in

the design of mechanical and electrical systems which conserve

energy. The procedural standards shall address, when applicable,

the following items:

(1) insulation,

(2) lighting, according to the lighting necessary for the

tasks for which each area is intended to be used,

(3) ventilation,

(4) the potential use of new systems for saving energy in

ventilation, climate control, and other areas, and

(5) any other item wh^ch the State Building Commission

deems appropriate.

A NEW APPROACH

The staff had a legislative mandate to produce standards which

had seemingly contradictory requirements in that both performance and

procedural standards were required. However, the legislative intent

was understood to be to minimize any adverse impact of the new

standards on the design process. A compromise solution was sought

whereby a new standard might be developed which would address the concerns of the specific group most impacted by each section of the

standard

.

ASHRAE 90-75 was recognized as a valuable energy conservation

design standard, yet some did not consider it to be suited to all the

requirements of the law. ASHRAE 90-75 was as vigorously opposed by

many architects as it was supported by many engineers. The solution

to this lack of consensus seemed to be to use 90-75 as the basis for

those sections most directly affecting the engineers and develop a performance standard for the building shell which would reflect the

energy efficiency of the design alternatives available to architects.

The State Design Standard which grew out of this compromise

contains five (5) sections covering the following:

Subdivision 35 of Article 1175, Revised Civil Statutes of

Texas, 1925.

193

i
1) building shell

2) mechanical systems

3) mechanical equipment

4)^ J

<if^T"\7"i p^=» w^i 1" p T" fiPj^1"Tno

5) lighting

The mechanical systems, mechanical equipment, and service water

heating sections are very similar to ASHRAE 90-75 and were considered

acceptable by the engineering professionals. The lighting section

differs from 90-75. It provides for a lighting budget based on watts

per square foot allowable for the different tasks within an area. The

allowable power levels for different tasks have been compiled and

listed in a tabular form. Additional requirements are made on switching and reduced levels of illumination for maintenance.

Additional flexibility is provided since some task areas are designated in foot-candles with a maximum allowable of 3 watts per

square foot, and exemptions are granted for special purpose areas like

stage lighting. The lighting section is modeled after work done in

California. It was chosen over the lES method due to the ease of

checking compliance.

The most controversial and most innovative section of the

standard is the section on the building shell. The development of

this section grew out of the concern of the architectural profession

and the requirement for a performance element in the Legislation. The

remainder of this paper will be used to explain the methodology and

application of this performance design standard.

PERFORMANCE STANDARD

The building shell section is based on compliance with what is

called an Envelope Energy Index (EEI). The EEI is not intended to

specify energy consumption, but to provide a comparative value for

determining the relative energy efficiency of a building shell. The

standard assures a minimal thermal performance of the shell by

specifying an EEI as a function of building size and location. The

standard EEI values were established using a prototypical building

with square floor plan and a number of floors which tended to minimize

the surface area of the building. The wall and roof U-value were taken from ASHRAE 90-75. It was also assumed that 30% of the wall

area would be single glazed and have a shading coefficient of

one-half. These assumptions do not prescribe the shape or amount of

glazing in a building, they simply establish a target EEI value. The

EEI has units of millions of BTU per year. There will be many

combinations of building shape, orientation and materials which will

meet the EEI values for the specified enclosed space.

Compliance with the standard may be determined by the architect

during the preliminary design. In fact, the EEI method may be a very

194
useful design tool in aiding the architect in the initial design

phase. The EEI accounts for the influence of geometric factors,

climatological variables associated with the location such as temperature and solar irradiation, and the effect of internal loads.

The EEI method employs standard procedures for calculating

heating/cooling loads. However, in this procedure these loads are calculated on a daily, rather than hourly basis, and are correlated

with daily average temperature. A number of studies have shown that

the average dry bulb temperature provides the best single measure method for comparing envelope loads. It was felt multiple measure

correlations would be too complex for practical application. The

daily loads were utilized as they minimize the complexity of the

calculation procedure. On a daily load basis, the mass or thermal

capacitance, of the envelope has little effect, thus providing a significant simplification. The procedures for including solar and

internal loads are also simplified. (The hourly design load for

sizing equipment must be calculated separately as this procedure will

not provide appropriate loads for that purpose.)

EEI CALCULATION

The thermal performance of any particular building envelope may

be represented graphically as a function of BTU's transferred and

daily average temperature as shown in Figure 1. The daily load curve will be a linear function of average daily temperature, therefore, the curve may be described by two points. Daily loads are calculated for

two days, one for a summer day representative of average conditions in

July, and one for a winter day representative of average conditions in

January.

The daily loads are determined by using daily sums of the total

equivalent temperature differences and solar heat gain factors

described in the ASHRAE Handbook of Fundamentals 1972. In the present

procedure, TETD and SHGF values must be corrected for percent possible

sunshine, surface color coefficient, and an ambient dry bulb

temperature profile different from that on which the Handbook tables

are based. This must be done as daily envelope loads are to be

compared on the basis of average conditions rather than peak load

conditions. The correction procedure, however, is very simple and is

Daily load

Equivalent temperature difference *^F

Total irradiation on a surface BTU/hr.

Total daily irradiation on a surface BTU/day

Area of perimeter spaces

outlined below:

Terms : QD

ETD

It

"^DT A

P

195
= Outside air temperature °F

t^ = Inside air temperature °F

"Vh = Color correction factor

%S = Percent possible sunshine

sc = Shading coefficient for windows (include both

internal and external shading)

Load for Roof and Walls :

Equivalent temperature difference

ETD = t - t, + (!_,) %S

o 1 hi

Daily sum lETD = (t^- t.) 24 + ^ (Ij^^) %S

Daily load for wall or roof Q^^ = UA (2ETD)

Load for Windows :

Transmission = U A (t - t.) 24

g g

^ oa \'

Solar = A^l^^^ (SC) (%S)

Daily load for glass Qj^^ = + Qg

Internal Loads :

In this procedure, only the internal load in the perimeter

zones will be assumed to interact with the building

envelope. For calculation purposes, the perimeter zones will be assumed to be 15 feet deep.

Internal Loads

2

Lights Q = (watts/ft. ) (3.413) A (hours of

P - \ operation)

Equipment Q = (same form as lights)

E

People = Ap/150 (400 Btu/hr) (hours of occupancy)

This assumes an occupancy of one person per 150 square feet.

Total Daily Load Q^^^ = % + + ^E %^

A series of graphs provide the index as a function of building

size for each of 15 climatological areas of the State. Once an EEI

has been established from the appropriate graph for a particular

196
building size and location, a proposed building design may be checked

for compliance. An architect may evaluate his building during the

preliminary stages by calculating Q^^ for January and July and

plotting the building load curve. A preliminary comparison is then

made between the proposed building and standard by taking the January

and July value from the appropriate graph for the same size building.

Typically visual inspection will indicate if the proposed building is

in compliance. If the building is close, compliance may be determined

by establishing the proposed building load curve in equation form Y = aX + b. Simple substitution into the equation of the average monthly

temperature for X will yield Q^^ for the other ten months. The

summation of the Q^^ for each month multiplied by the number of days

in each month provides an index value to compare with the EEl taken

from an appropriate graph such as Figure 2. If the summation for 12

months is less than the EEI, the building complies; if it is greater,

modifications of the building shell are required.

By plotting the end points of the standard building envelope load

curve using graphs like Figures 3 and 4, the architect may establish a baseline for comparing design alternatives and visually inspect

superior designs as shown on Figure 1. The Energy Conservation Manual

has a standard data sheet shown as Figure 5 and a calculation form to

provide ease of calculations as shown in Figures 6, 7, and 8.

Additional calculation aids are provided in the Manual on thermal

resistance of building materials and shading factor calculation aids.

CONCLUSIONS

The standard has been adopted for use in Texas on State buildings

and is being tested for one year to allow for comment by professionals

involved in State construction and to allow staff evaluation of

enforcement difficulties. This approach toward energy conservation

design standards is admittedly evolved from controversy and founded on compromise. Amendments and updating will be necessary but this

standard provides a precedent for performance standards which can be

quantitatively determined and satisfied before construction and

provides little or no obstruction to the design and construction

process

.

Initial experience with using the EEI standards indicates most

buildings comply without changes. Future changes in the indices are anticipated to encourage more efficient design.

197
CHART A- DETERMINING AVERAGE MONTHLY COOLING - HEATING VALUES

30 «0 50 60 70 80 90 100

MEAN AVERAGE MONTHLY TEMPERATURE Figure 1

198
CHART A-4-B

ALLOWABLE EEI FOR BUILDINGS - AUSTIN

1000 10,000 100,000 1,000,000

BUILDING SIZE - SQUARE FEET

Figure 2

199
001 01 SNoniiN - s.nis i I'

001 01 stwmiK - s.nn i r

200
201

sat

Si

7

_

0

<5

lA

8

203
204
THE NEED TO IMPLEMENT ENERGY CONSERVATIVE INSULATION STANDARDS

BASED ON AVERAGE ENERGY USE R/vTHER THAN PEAK ENERGY USE

- THE NEW MEXICO EXPERIENCE

by

I Wybe J. van der Meer, P.E., R.A.

Associate Professor, School of Architecture and Planning

Director of the Division of Energy Conservative Design

University of New Mexico

Albuquerque, New Mexico

audi

Larry W. Bickle, PH.D., M.E., President

L.W. Bickle & Associates, Consulting Engineers

Albuquerque, New Mexico

All Federal insulating standards for residence walls, ceiling and

glazing are based on steady state U-values which govern the heat

transfer rate only under conditions of peak energy use. Even the

Component Design section of ASHRAE Standard 90-75 considers only

steady state U-values as the basis for their requirements at arriving

at stipulated average heat transmission values. Theoretical studies

on heat transfer through walls and glazing, and studies of actual

energy use for heating for a group of approximately 20 residences of

different insulation amounts, made by the authors for the New Mexico

Energy Resources Board, indicate that while added insulation may

reduce heat transfer during peak energy use periods there is no proof

that insulating for peak energy use periods reduces the overall or average energy consumption during the heating season. Quite the

contrary, we find that insulation, for peak energy use may be

counterproductive and result in a greater amount of energy used for

the heating season than if one insulates for average energy use conditions

.

Key Words: ASHRAE Standard; climatic conditions; energy

conservation; glass area; heat transfer; insulation;

standards; U-values.

i

205
All Federal insulating standards for residence walls, ceiling and

glazing are based on steady state U-values which govern the heat

transfer rate under conditions of peak energy use. Even the Component

Design section of ASHRAE Standard 90-75 considers only steady state

U-values as the basis for their requirements for stipulating average

heat transmission values. Theoretical studies on heat transfer

through walls and glazing and studies of actual energy use for heating

for a group of 25 residences of different insulation amounts, made by

the authors for the New Mexico Energy Resources Board, indicate that,

while added insulation may reduce heat transfer during peak energy use periods, there is no proof that insulating for the peak energy use periods reduces the overall or average energy consumption during the

heating season. Quite the contrary, we find that insulating for peak

energy use, in some instances, may be counterproductive and result in

a greater amount of energy used for the heating season than if one insulates for average energy use conditions

The ASHRAE "Component Design" section and recent actions by the

Federal Housing Administration of HUD in increasing insulation

requirements and limiting glass areas, promulgate the conception that more and more insulation and less and less glass area will lead to

energy conservation. In New Mexico we have not found this concept to

have much validity for average energy consumption in heating and we are inclined to wonder whether the concept has much strength for even

a majority of the continental United States.

If more and more insulation were categorically better, then why

is there so little correlation between insulation quantities for walls

and ceilings and average energy consumption for heating the

twenty-five houses we studied in Albuquerque? See Figure 1. (A

linear regression program to determine the "best fit" straight line

for the data, produced an almost horizontal line, slope of -1.7** and

only a -0.08 correlation coefficient; the combination of which is so weak that we omitted the line from Figure 1). Dr. Jay McGrew,

President of Applied Science and Engineering, Littleton, Colorado,

could find no correlation at all between ceiling insulation quantities

and energy consumption in a study of over 30 houses in the Denver

area. See Figure 2. Now in case you have already formed the opinion

that this lack of correlation applies only where the sun shines

profusely, then how does one account for the presentation made by

Dr. Bonnie Haas Morrison to this same group last year? In a study of

single family homes in randomly selected urban and rural areas of

mid-Michigan the Standard Regression Coefficient for insulation in the

walls versus amount of direct total energy consumed was only -0.096,

and for ceiling insulation was only -0.161. The "Belief in the Energy

Problem" was very nearly^ as strong a correlation as the wall

insulation (see Figure 3).

From: "Residential Energy Consumption: Socio-Physical

Determinants of Energy Use in Single Family Dwellings," by Dr. Bonnie

Haas Morrison, NBS Special Publication 473 , June, 1977.

206
The State of New Mexico is one of the first to adopt Chapter 53

of the Uniform Building Code, which is based essentially on the ASHRAE

Standard 90-75. However, it was considered that our climatic

conditions of high percentages of sunshine and large diurnal

temperature differences could significantly affect the way wall, roof

and glazing components perform with respect to their steady state

U-values. Chapter 10 of ASHRAE Standard 90-75 allows exceptions to the

insulation requirements if there are supporting calculations to show

equal or better performance. For homes and small projects, however,

it is unlikely that the owner or builder can afford the cost of

professional engineering analysis that would be required for each

exception. Therefore, the State of New Mexico Energy Resources Board

sponsored a research contract for the authors to investigate the

actual performance of typical wall components and glazing components

under New Mexico climatic conditions, for use by designers and

builders of residences and small projects in lieu of the steady state

U-value insulation requirements.

In order to perform the required theoretical calculations, we have developed a one-dimensional computer model that uses actual

hour-by-hour weather data and "first principle" heat transfer

relationships to compute heat transfer through walls and glazing.

This program is described in more detail in Appendix A.

A significant aspect of the computer program is that it keeps

track of the average heat flux at the inside surface of the wall over

an extended time period (i.e., one or two weeks). This average heat

flux is used with the average difference between inside and outside

temperature to compute an "Effective U-Value" which is a measure of

the average rather than the peak heat transfer characteristics of a wall or other surface. We think that this concept of an Effective

U-value is an important contribution to understanding the problem of

energy conservation in structures.

In order to develop insight into the influence of storage mass,

color, orientation, diurnal temperature differences, etc.; the

computer program was run for two different glazing types with three

different inside treatments and for twenty-seven (27) wall types for

the eleven (11) different climatic regions of New Mexico and the four

(4) cardinal points of orientation (i.e., North, South, East, and

West)

.

Although the work to date is not complete, the results so far

show some interesting trends

.

GLAZING

Our computer results indicate that even single glazing (with

night time treatment of drawn dense drapes) can be a net energy gainer

for South, East, and West orientations in the majority of New Mexico's

climatic regions (to approximately 5300-degree days, heating). Single

glazing, even for north windows without night time treatment, appears

to perform much better on an average than the steady state U-value

would indicate. See Figure 2 of Appendix A.

207
Our survey of houses in Albuquerque confirms the potential energy

conservative aspects of glazing. In fact, the houses that we studied

showed, that for glass areas between the ranges of 7.8% of the floor

area and 16.3% of the floor areas, that the greater the glass area the

less energy consumption for heating. See Figure 4. The Correlation

Coefficient of -0.56 seems surprisingly strong in view of the facts

that:

1. The houses had random orientation.

2. The majority of the houses had single glazing.

3. The houses had varying insulation quantities.

4. The effects of life style and furnace efficiencies on consumption must also be considered.

COLOR

The computer studies show that the Effective U-values for walls

are a strong function of color (absorptivity) , even for North

orientations. See Figure 5.

In our housing survey, although the glass correlation was quite

strong, an even strongexN correlation was found in our study to exist

between a color factor for walls and roof and energy consumption.

See Figure 5. The Slope of -0.41 and Correlation Factor of -0.674 is

very strong considering all the variables of the houses. The negative

slope and correlation factor indicates that the darker the color

factor the less energy consumption.

Possible Net Energy Gainers

In addition to glazing, we have found that some wall types in

certain circumstances appear to have the potential to be net energy

gainers. Dark unfilled concrete block walls computed as energy gainer

for two of our regions (see Figure 6) while log walls in dark colors

computed to be energy gainers in several regions. (See Figure 7.)

Color - , „Factor ^ _ Wall Area ^ , Roof Area „ v mo = LTU/^Day ^ ^ BTU/^Day ^ ^2

Where

a^ = absorptivity of wall

a„ = absorptivity of roof

BTU/°Day = average actual energy for heating in BTU per

Degree Day

208
SUMMARY

Our work for New Mexico has been entirely devoted to the

performance during the heating season since in this state evaporative

coolers work so effectively while using less energy than most major

household appliances. But even for the heating season our work is not

yet completed. We have been funded by the New Mexico Energy Resources

Board to conduct experimental heat transfer studies during this coming

heating season and thus verify or (if necessary) modify our computer

program. However, we think that our work to date is sufficient to

cast serious doubts as to the wisdom of traditional thinking with

regards to insulation and glazing policies. We are encouraged by the

correlation using Effective U-Values that we have achieved between

calculated average energy for heating and actual energy used for

heating of the houses surveyed, as opposed to the correlation between

steady-state U-value calculations and actual energy consumption. See

Figures 8 and 9. Not only is the correlation stronger, but the slope

of the correlation line for the Effective U-Value comparison is much

closer to the desired correlation line. The better match of desired

and "best fit" correlation lines appears to reflect the fact that the

average estimated consumption of the houses, by the Effective U-Value

method was only 6% lower than the actual consumption while the average

of the estimates using steady-state U-values was 40% higher than the

average actual consumption of the houses. The 6% low figure can, to an extent, be explained by differences in furnace efficiencies,

life-style of occupants and quality of workmanship of the houses. But

the 40% high figure is difficult to explain without questioning the

applicability of steady-state U-Values to average energy consumption.

209
ACTUAL ENERGY OUTPUT

VERSUS

AVERAGE R-VALUES

FIGURE NO.

i:

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211
NET ANALYSIS

Total Direct EiTergy OorisurTptlon

Table 2 — Standardized Begressicn Coefficients, F-ratioe, Probability of Soipling

Errco: and Multiple Oorrelaticns of Seventeen Independent Variables cn

the Amount of Direct Total Energy Ccnsoned in Single Fanvily Detached

Dwelling Units.

Arount of Direct Itotal E^iergy

OcnsvxQod

Probability of

Saipling £rxor.

Independent Variables 0 F One Tailed Test

Household size .280 8.02 < .001

Major appliances .211 3.19 < .01 Mmber of roans .173 1.30 • .25 Munter of exterior doors .168 2.38 < .05 Number of roans heated .165 1.71 < .25 Square feet .081 .56 » .25 Family gross inoone .064 .35 » .25

Nii±er of floors .055 .37 » .25

Nattier of winders .049 .24 » .25 Insulation - floors .027 .94 » .25 Ocnstructicn naterials .024 .73 » .25 Fanily life cycle stage .024 .58 » .25

Nixober of roans air cand. -.007 .56 » .25 Belief in energy probleri -.095 1.02 > .25

Insulation - vails -.096 1.00 > .25

Location (rural/urf»n) -.127 2.14 < .05

Insulation - ceiling -.161 3.41 < .005

Overall F 4.38 < .0001

R .696 df regression 17 - .485 df residual 79

The interesting outoane of the stepwise regression was the total anount of variance

2 •Kplained (R - .485) and the cutocrne ordering.

FIGURE 3

212
ACTUAL ENERGY OUTPUT

VERSUS

WINDOW TO FLOOR AREA

FIGURE NO.

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ACTUAL ENERGY OUTPUT BTu|sF|°rAY

7TT
ACTUAL ENERGY OUTPUT

VERSUS

HOUSE COLOR FACTOR

FIGURE NO.

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ACTUAL ENERGY OUTPUT BTu|sFj°DAY

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(UNFILLED)

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1 .290 .234 .175 .277 .202 .119 ^264 .158 . 052 .279 .201 .124

2 .275 .245 .214 .266 .223 f 179 .255 .194 . 133 .268 .226 .185

3 .272 .247 .223 .263 .226 .190 .252 .198 . 145 .265 .231 .197

4 :|.270 .250 .232 .260 .226 ,195 .246 .195 i. 143 .262 .233 .204

5 1.270 .251 .232 .259 .225 ,193 .245 .191 :. 137 .262 .232 .203

6 1.270 .251 .232 .258 .222 ,188 .243 .185 . 125 .262 .230 .199

7

1 .272 .251 .231 .258 .219 ,181 .241 .176 . 109 .262 1.228 .193

8 .274 .250 .227 .258 .212 ,168 .238 j.l62 . 083 .263 .222 .181

9 .278 .249__ .j21_ .J59__ .204 ,150 .236 .145 1. 049, ^264_ .215 .165

10 1.284 .247 .210 .260 .190 119 .232 .115 !- 008 .267 .203 .136

|.284 .245 .201 .262 .181 097 .231 .096 |- 047 .269 .194 .117

LUflLL COLORS: L=LIGHT

m-m€Dium

D=DflRK

NOTh: ALL ENTRIES IN THE TABLE ARE

PRECEDED BY "0". THAT IS: .122 = 0.122; -122 = -0.122

FIGURE
SPLINE

OUTSIDE

FOAM

I NSULATION

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NSIDE

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PINE LOG

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NOTE: ALL ENTRIES IN PRECEDED BY "0"

.122 = 0,122; -

THIS TABLE ARE

. THAT IS: 122 -0.122

FIGURE 7

216
ACTUAL ENERGY OUTPUT

VERSUS

CALCULATED ENERGY USE

FIGURE NO.

8

ACTUAL ENERGY OUTPUT btu1sf|°C)ay

217
ACTUAL ENERGY OUTPUT

VERSUS

CALCULATED ENERGY USE

14 12 10 e 6

ACTUAL ENERGY OUTPUT

FIGURE

9

NO.

BTU SF rOAY

215
A STUDY OF THE EFFECT OF EXISTING ENERGY CONSERVATION

REGULATIONS TO ASSIST IN THE SELECTION OF MORE COMPREHENSIVE

ENERGY CONSERVATION STANDARDS

by

Charles H. Fafard

Wisconsin Department of Industry

Labor and Human Relations

Madison, Wisconsin

The State of Wisconsin has had, since 1914, a statewide

Administrative Building Code, administered and enforced by the

Department of Industry, Labor and Human Relations (DILHR) . This code

regulates construction of all buildings except one- and two-family

residences, farm buildings and temporary buildings. The rules

contained in the code carry the stature of law.

An Energy Conservation Advisory Committee was appointed to DILHR

by the Division Administrator, John Wenning, in December 1973, at the

peak of the energy crisis. The committee made several recommendations, including lowering of inside temperatures and reducing the

minimum ventilation from 7.5 c.f.m/person to 5 c. f .m/person. The

committee also recommended a thermal performance standard which

limited the heat loss through above-grade envelope areas to 13 Btu's

per hour per square foot. These recommendations were incorporated

into the Wisconsin Administrative Code in stages in 1974 and 1975.

The thermal performance requirements generated strong opposition in

the glass and masonry industries. These groups convinced a committee

within the Wisconsin State Legislature to rescind the thermal perfor- mance section (May 1975) after five months of enforcement. The

thermal performance requirements were reinstated in April 1976, when

the full legislature did not act on the permanent suspension of the

rules

.

Key Words: ASHRAE Standards; building envelope; building

regulations; data collection; energy budget; energy

conservation; heat loss; thermal performance.

219
The State of Wisconsin has had, since 1914, a statewide building

code. The Wisconsin Administrative Code is enforced by a centralized

plan examination staff and a field inspection staff under the

Department of Industry, Labor and Human Relations (DILHR) . All public

buildings and places of employment within the State are required by

Wisconsin Statutes to comply with the Wisconsin Administrative Code.

Since January 1974, the State of Wisconsin recognized the energy

shortage and steps were taken to reduce the amount of energy consumed

in buildings. At that time, indoor design temperatures were reduced

(offices and living areas were set up at 67*^., retail areas at 65°F.)

and the ventilation air requirement was reduced to 5 cubic feet per

minute (from 7.5 CFM) per person. On January 1, 1975 a further and more significant energy conserving requirement was added to the code.

The thermal performance requirement limited heat loss (excluding

infiltration and ventilation) in above grade gross walls and roofs

facing heated interiors to not exceed 13 Btu's per hour per square

foot of total building envelope.

The thermal performance rule generated much controversy from

special interest groups (particularly the masonry and glazing

industries) during its first few months of application. These groups were more concerned over possible decreases in sales than in energy

conservation, and they pressured the Wisconsin State Legislature to

repeal the rule. The rule was suspended by a Legislative Committee on May 29, 1975. However, the full Legislature failed to confirm the

rule suspension and it went back into effect March 26, 1976. The rule

has been in effect continuously since that time.

During the last several years, many energy conservation standards

have been suggested or proposed. We have seen standards based on a budget approach (such as the State of Ohio's total connected energy

load standard), a prescriptive approach (such as ASHRAE Standard

90-75) and performance standards (such as Wisconsin's Thermal

Performance requirement). It has been thought that Wisconsin's

thermal performance requirement has saved considerable energy in

buildings, even though it deals only with conservation in the exterior

envelope. In spite of the effectiveness of the current rules, the

State of Wisconsin has considered adopting the more comprehensive

energy standards listed above.

The method of conserving energy differed for all three standards,

but all three contain provisions to limit the heat loss through the

building envelope. (The total connected load approach sets a limit to

the HVAC equipment output capacity plus the lighting load, which will

tend to reduce the heat loss through the envelope. The concept is the

less the connected load, the less energy consumed.) To evaluate the

standards against each other is difficult, as the three do not cover

the same areas. Because the thermal performance requirement covers only the envelope heat loss, this area will be covered in detail.

To compare the standards, energy related data was collected from

building, heating, ventilating and air-conditioning plans that were submitted to DILHR for approval during the years 1973 and 1977. This

220
approach was to illustrate energy consumption in buildings prior to

the energy crisis (1973 plans) and the current year (1977 plans) of

energy awareness. Because of the small number of high rise buildings

built in any one time span, additional data for high rises was collected from as far back as 1964. The number of plans that were evaluated follows: 1973--542; 1977--154; and 28 high rise buildings.

The information that was gathered was computerized and analyzed for

comparisons of design philosophy between the years mentioned above,

energy conservation measures added to the Wisconsin Administrative

Building Code since 1973, and for comparisons of the present thermal

performance requirement (13 Btu's per hour per square foot), the

ASHRAE 90-75 Standard, and the Ohio total connected load concept.

In reviewing the total connected load budget, many questions of

validity arose. By definition, the total connected load is "the total

lighting load plus the total output capacity of all terminal heating

units or the total building lighting load plus the total output

capacity of all terminal air-conditioning units, whichever is

greater." The capacity of the terminal units is to include output

capacities of coils, the energy input to supply and return air fans,

and the energy input to pumping equipment necessary for coil control.

The connected load appears to be comprehensive; however, the following

are to be excluded from the connected load: 1. Noncritical energy

(recovered or renewable energy); 2. Energy for the operation of

building emergency or standby equipment; 3. Energy used for purposes

other than lighting, heating, ventilating or air-conditioning;

4. Energy required to make up air for kitchen exhaust, paint booths,

dust collectors, industrial exhaust and similar installations; and

5. Energy for heating, ventilating or air-conditioning systems which

are used exclusively for the purpose of overcoming process loads. The

list of exclusions is extensive and can account for a sizeable

percentage of a building's total energy use.

Item 3 above separates a building's energy use into two basic

categories: 1. Energy related to control the building's environment,

and 2. All other energy, including energy which can be attributed to

the occupancy of the building (i.e., typewriters, computers, domestic

water heaters, etc.). This non-environmental energy is excluded from

the total connected load.

The 4th item above indicates that any energy expended to temper

makeup air can be excluded from the total connected energy load. This

severely limits this proposed code, as many buildings consume more energy in providing tempered makeup air than in any other area. In

many areas, it may not be easy to separate the ventilation requirements from the heating specifications. Also, the Wisconsin Building

Code allows situations where air may be transferred from one area to

another, causing possible difficulties in determining whether to

exclude the energy consumed in tempering the outside air.

In item 5 above, the process loads referred to have been exempted

by item 3. Any additional energy consumed by a heating, ventilating or air-conditioning system to control the environment by offsetting the

process loads is exempt by this item. This can provide an "energy

221
loophole" of sizeable magnitude, as process loads can be several

magnitudes larger than the building's construction loss. This item

also poses problems for plan review, as a subjective decision will

have to be made to determine the purpose of each heating unit.

Heating and cooling units many times are used to offset many loads

(construction, infiltration, ventilation as well as process loads),

making it difficult to subdivide units by function.

The total connected load budget establishes an energy allotment

figure for all occupancies. The total connected load, when divided by

the total floor area, is not to exceed the adjusted allotment figure.

The adjustments are for the building design, size and location.

Specifically, these adjustments are for total floor area, number of

levels, level height, and degree days for the building location. The

following criteria was used in developing the adjustments: 1. Building area of 50,000 square feet; 2. Building height 14 feet, one

story; 3. Square building configuration; 4. 10 percent of exterior

walls in glass and doors; 5. Building transmission characteristics:

a. roof = 0.10; b. net exterior walls = 0.10; c. windows = 0.56; d.

slab edge = 45 Btu/linear foot; 6. AT = SO'T. Adjustment equations

(shown in Table 1) were developed by varying the above criteria in an attempt to encompass all building types. The allotment figures,

adjustment criteria figures and corresponding equations were not

conclusively shown to be presentative of actual building design and

energy use. For example, as shown in Table 3, the average percentage

of windows alone for the years 1973 and 1977 exceeds the

10 percent theoretical unit mentioned above.

The basic adjustment criteria are not representative of building

design. The U-values appear to be the only item that is realistic;

however, masonry walls would have to be well insulated to achieve a U-value of 0.10 Btu/h per sq. ft. per °F. The other items are not

necessarily typical of building design, and attempting to apply one

set of theoretical criteria to all buildings is unrealistic.

It is important to remember that the budget approach includes

energy for heating and cooling equipment, ventilation fan loads and

illumination. The total connected load figure is divided by the total

floor area of the building and then adjusted by the above mentioned

equations according to the building geometry. Therefore, all items

comprising the total connected load are adjusted for floor area,

number of stories, story height, and degree days. This approach is

incorrect, as not all of the elements comprising the total connected

load are functions of the adjustments. The lighting energy is a function of the occupancy and, therefore, the total floor area of a building (assuming that the lighting is designed on a task basis in

footcandles) ; it is not dependent on story height, number of stories

or degree days. In addition, the ventilation energy would not be a function of story height, number of stories, or total floor area. The

lumping of various energy users together and then adjusting this

figure results in adding an undetermined error to each calculation.

Also, one of the original criteria for the allotment figures was a AT of 80°F. However, in the adjustments, degree days are used. This

is confusing as there is no direct or easy correlation between annual

degree days and the design temperature differential.

222
As indicated above, the budget approach has many drawbacks, but

one of the most serious pertains to the mechanical systems. The basic

concept of the budget is that the less the connected load, the less

the energy used. However, this rarely applies to mechanical HVAC

systems, in that the connected load is required to meet the needs on peak design days. Furthermore, the energy efficient system is

designed to operate more efficiently at partial loads (which makeup

80-95 percent of the operating hours in each year) and frequently with

relative inefficiency at full load. Thus, the energy efficient system

can have a larger connected load than a much less efficient system.

Since compliance with the allotment figure is dependent on the size of

the mechanical system, this rule will encourage use of less efficient

systems. Therefore, the total connected load budget actually

restricts energy conservation. In addition, many buildings are designed to accommodate future additions. In many of those buildings,

the heating system is sized for the future load as well as the

existing load. Because the total connected load budget limits the

output capacity of the HVAC equipment, this approach would not permit

the use of oversized equipment. Instead, a separate HVAC system would

have to be provided when the additions were built. Therefore, all the

inefficiencies of the HVAC system would be doubled by a second system

for these buildings.

In reviewing the computer program for all occupancies, compliance

with the total connected load concept went from 46 percent (247 of

539) in 1973 to 66 percent (77 of 116) in 1977. (It has to be

remembered that many of the buildings evaluated did not contain

lighting data or plans. Therefore, the total connected loads for

these buildings were calculated without a lighting load, which can account for 20 to 40 percent of a building's energy load.) This

improvement in compliance can be due to many factors, including

changes in design practice due to energy awareness (such as lower

U-values in construction) and changes in code requirements (reductions

in design temperatures and lower outside ventilation air quantities).

For these two years, the summation of all heating equipment output

capacities divided by the summation of the total heat losses

(hereafter referred to as the heating overdesign factor) increased

from 1.29 in 1973 to 1.81 in 1977. This increase would appear to

contradict any energy saving philosophy, but actually this change is

not unexpected. On closer inspection, the heating overdesign factor

is controlled by many variables, as shown:

Overdesign Factor = Total Heating Output Capacity

Total Heat Loss

which breaks down into

Overdesign Factor = Total Heating Output Capacity

Construction Loss -t- Ventilation + Infiltration

substituting in equations yields

Overdesign Factor = Total Heating Output Capacity

(U Total X A Total xAT) + (1.08 x CFM xAT) + (1.08 x CFM x AT)

Vent. Inf.

223
The denominator will be reviewed as three separate sections

starting with the construction portion. The temperature differential

(AT) depends on the inside and outside design temperatures. Since

1973, both code sections covering these areas have been numerically

reduced, the extent depending on the particular occupancy and

location. The total area will be assumed to be constant for both

years. The U total value will undoubtedly decrease, due to reductions

in the percentage of window areas, increasing use of insulating

windows, and increasing use of insulation. The combination of these

factors will result in a general reduction in the construction loss

from 1973 to 1977.

The next two sections are closely similar, but the CFM amounts

are derived differently. For ventilation, the CFM quantity is

determined on a square footage or per person basis. For infiltration,

the CFM value is often calculated by the designer on an air change

method, generally ranging from one-half to one air change per hour.

This value will be assumed constant over the years. The ventilation

requirements for human occupancy have decreased since 1973 from 7-1/2

CFM/person to 5 CFM/person. Also, as mentioned above, the temperature

differential has decreased numerically since 1973. Infiltration

requirements have also been added to the code since 1973, which has

resulted in reduced infiltration losses. These reductions will

decrease the overall losses associated with the ventilation and

infiltration quantities.

As shown above, many of the terms in the denominator have

decreased, so that the overall effect will be a reduction in the

numerical value of the denominator. The numerator, the total heating

output capacity, is dependent on the total losses. This value has to

be equal to or greater than the total losses. Since the over-design

factor is larger in 1977 than in 1973, it appears that the numerator

(the heating output capacity) is not being reduced as quickly as the

calculations for the heat losses are. There appear to be two possible

answers to this: 1. The heat loss calculations are being influenced

by the thermal performance requirement, and therefore, the traditional

"factor of safety" is being removed from the calculations by the

designer. However, this "factor of safety" may be accounted for by

providing equipment with larger capacity outputs. 2. The use of more efficient HVAC equipment that is sized for the full building load at

partial capacity. Therefore, its total output may be higher than less

efficient equipment operating at full load.

In summarizing the review of the total connected energy budget

approach the following are major criticisms: 1. Energy for makeup

air is excluded; 2. The connected load adjustments are not based on actual building construction; 3. The adjustments are incorrectly

applied, resulting in varying values that are actually constants;

4. By limiting equipment sizes, this approach can require that less

efficient HVAC systems be specified for buildings; and 5. Many

sections of ASHRAE Standard 90-75 (such as HVAC equipment efficiencies, HVAC system design, service water heating and lighting power

budget) are not covered by the budget.

224
The Wisconsin Thermal Performance Standard limits heat loss

through above grade envelope areas to 13 Btu's per square foot of

envelope area per hour. This value is consistent for all buildings

within the jurisdiction of the Wisconsin Administrative Code. This

requirement has incurred much criticism since its inception to the

code in January 1975, and it was for a period rescinded. However, it

has been continuously in effect since April 1976. One criticism that

still plagues this requirement is that it is overly restrictive on high rise buildings. The thermal performance value is comprised of

U-values and areas for the gross walls and roof. As the number of

stories of a building increases, the gross wall area percentage

increases and the roof area percentage decreases. The roof area,

because it is a blank area, generally has a lower U-value than the

gross wall area (with its various openings for windows and doors).

Because the thermal performance requirement has a finite value, a limit to the acceptable number of stories is reached, as shown in

Figure 1. This graph compares the calculated thermal performance

value vs. the number of stories for buildings prior to the 13 Btu per

hour per square foot rule. As can be seen by the graph, there is a general upward trend in thermal performance as the number of stories

increase. One surprising fact shown by the graph is the relatively

large thermal performance value for one story buildings. This can be

assumed to be from large percentages of glazing in certain one story

buildings (such as showrooms) and also buildings that are typically

poorly (or not at all) insulated, such as warehouses.

The effectiveness of the thermal performance requirement is

illustrated by Tables 2 and 3 which show the changes in the thermal

performance value and the total heat loss per envelope area from 1973

to 1977 in tabular form. These changes are due mainly to the limiting

of the construction loss per envelope area to 13 Btu's per hour per

square foot of envelope area, although other code changes (such as reductions in design temperatures and ventilation amounts) have also

contributed to the changes. As seen by the Tables, every occupancy

saved energy (construction loss as well as total energy) from 1973 to

1977.

As shown by Figure 2, the construction loss (which is limited by

the Thermal Performance requirement) decreased from 53.2 percent in

1973 to 50.4 percent of the total building losses, a reduction of 5.3

percent. The floor loss was reduced 11 percent, the ventilation load was reduced 24.7 percent, but the infiltration increased as a percentage of the total loss by 44.4 percent. This can be attributed

to the fact that the infiltration was not controlled by building code

rules, and the numerical value did not decrease. Meanwhile the total

loss was decreasing from 1973 to 1977 by 56.7 percent, which results

in an increased percentage for infiltration.

A frequent criticism of the thermal performance requirement has

been that it restricts the use of glass in a building. It is

interesting to note that the computer study shows that the window

area, as a percentage of the gross wall area, decreased only from 14.4

percent in 1973 to 12.2 percent in 1977. This decrease of only 15

percent occurs despite the fact that the heat loss through the

envelope area has decreased dramatically for 1977 buildings (see

I 225
Tables 2 and 3). The use of double and triple glazing has also

increased since 1973, as shown by Table 4.

ASHRAE Standard 90-75 sets limits on exterior heat loss (Section 4) by establishing maximum coefficients of transmission

(U-values) according to degree days. This is done for various

components of a building, such as gross wall and roof. In addition to

the U-values of the exterior envelope, ASHRAE also establishes heat

loss criteria for floors and heat gain criteria for the exterior

envelope, referred to as the overall thermal transfer value (OTTV)

The Arthur D. Little Company, Inc. (retained by the Federal Energy

Administration) analyzed the effects of ASHRAE Standard 90-75 on energy conservation. To make a comparison, they assumed five

prototypical buildings (single family residence, low rise appartment

building, office building, retail store and a school building) were built in four regions of the U. S. (Northeast--New York, North

Central--Omaha , South--Atlanta , and the West--Albuquerque) . They

assumed that the buildings were identical from region to region. They

also assumed that these buildings were built using approaches and

design practices prevalent during 1973. They then applied ASHRAE

Standard 90-75 to these buildings to illustrate what effect it would

have. The Arthur D. Little report notes that the reduction in energy

usage for single family residences is less than the other occupancies.

They conclude that this "may in part be due to the moderately high

overall thermal efficiency assumed for conventional residences" and

that the northeast and north central regions met the standard with

single glazing and a minimum reduction in glass area. Since single

family residences are not covered by the Wisconsin Administrative

Code, this phenomenon will not be further researched.

Table 5 compares the values developed by the Arthur D. Little

Company to those generated by the Wisconsin computer program. This

Table actually compares the effect of ASHRAE Standard 90-75 and code

requirements within the Wisconsin Administrative Code on 1973

construction. It must be remembered that the Arthur D. Little figures

are theoretical and that their regions of study differ climatically

from Wisconsin. Therefore, a strict one-to-one comparison cannot be

made, but rather a comparison of magnitudes must be made. Wisconsin's

reduction of energy on a thermal performance level is impressive as just the energy through the envelope is being compared. The reduction

in total losses (especially offices and schools) appears to be low,

but it must be remembered that buildings built in Wisconsin in 1973

may differ drastically from buildings built in other areas of the

United States in 1973. If Wisconsin's 1973 building code was more restrictive than other codes throughout the United States, then the

reduction in energy from 1973 to 1977 in Wisconsin would not be as great, and the percentages would be lower. This assumption can be

shown in the ventilation rates, as in 1973 Wisconsin allowed a minimum

of 7.5 cubic feet per minute per person. Most codes and design

practices were twice this value. It must also be remembered that

Wisconsin's code did not affect HVAC system design, HVAC equipment

efficiencies, service hot water or lighting design. All of these

areas will affect the energy consumed by a building and were included

by the Arthur D. Little Company in their analysis.

I

226
The Wisconsin computer data was broken down into four degree day

zones--?, 000, 7,500, 8,000 and 9,000. These degree day zones align

with the outdoor temperature zones currently used in Wisocnsin

Building Code, as shown in Table 6. The data, by degree day zones,

has been compared to the exterior envelope requirements specified in

ASHRAE Standard 90-75. Figures 3 through 6 illustrate how the means of

the Wisconsin data for 1973 and 1977 fared against the ASHRAE

requirements. As shown, the walls in 1973 ranged from approximately

40 to 55 percent compliance with ASHRAE to 91 to 100 percent

compliance in 1977. This would possibly say that the ASHRAE U-values

for walls is easily accessible for most buildings, and perhaps too

high of a numerical value for Wisconsin's climate. Roofs range from

approximately 3 to 16 percent compliance in 1973 to 36 to 58 percent

compliance in 1977. The low percentage of buildings in 1977 complying

with the roof U-values points to the ASHRAE value as being too

restrictive. Compliance with ASHRAE 's U-value for floors over unheated basements varied greatly for both years. Because the sample

of buildings with this condition was small, it is vertually impossible

to make any definite statement about this requirement. The slab

insulation resistance values range greatly, but it appears that

approximately one-third to one-half of all buildings with slab

insulation comply with the ASHRAE specification. It would be quite

simple to provide insulation with a higher resistance value so that

this area will comply with the ASHRAE Standard. The length (or depth)

of the slab insulation shows good compliance in 1973 and 100 percent

compliance for 1977. This area obviously does not need improvement.

To further analyze the ASHRAE Standard 90-75 envelope

requirements for Wisconsin, mean envelope data from the computer

program has been compared to the ASHRAE requirements, as shown in

Tables 7 through 11. These tables allow a one-for-one comparison of

U-values by degree days. It is interesting to note that many 1973

U-values, such as Type "A" gross walls, comply with the ASHRAE values.

In an attempt to correlate the thermal performance requirement

and the ASHRAE 90-75 standard, a relationship was developed using a "Typical" building developed by the computer for each number of

stories and the ASHRAE envelope requirements for the gross wall and

roof. The equation appears as follows:

Thermal Performance Value = (GWA) x (ASHRAE WALL) + (RA) x ASHRAE ROOF

ENVELOPE AREA

where

GWA = Gross Wall Area

RA = ROOF AREA

ASHRAE WALL = ASHRAE Gross Wall U-Value

ASHRAE ROOF = ASHRAE Roof U-Value

227
This equation was calculated for the four degree day zones and

ASHRAE building types ("A" and "B") and plotted in Figures 7 and 8. The data falls into smooth curves, with the exception of only a few

points. From the graph for Type "B" buildings it is easy to see that

the ASHRAE U-values for gross wall and roof produce thermal

performance values much higher than the currently enforced 13 Btu's

per hour per square foot. Because all public buildings and places of

employment currently designed have to comply with the 13 Btu per hour

per square foot rule, this graph also shows that the ASHRAE U-values

for gross wall and roof must be higher than would be currently

allowed. One other conclusion from this graph is that the present

thermal performance value is overly restrictive for high rise

buildings

Another conclusion from the Arthur D. Little report on ASHRAE is

that in the buildings they studied, glass areas were reduced in

approximately two-thirds of the buildings. The reductions ranged up

to thirty percent, but were generally twenty percent or less. The

effect of the existing thermal performance rule on glazing has been

compared to the effect of ASHRAE in Table 8. As illustrated in this

table, the Wisconsin data resemblies the data for the north central

region with the exception of the retail stores. If a trend can be

drawn from the ASHRAE figures, it appears, that as the number of

degree days increases, the percentage of glass area decreases." The

Wisconsin data would tend to confirm this finding.

In addition to the exterior building envelope section, ASHRAE

90-75 also has requirements on the HVAC systems, HVAC equipment,

service water heating, electrical distribution systems and lighting

power budget. This information is covered by Sections 4-9 of the

ASHRAE Standard. Since all of these sections are beyond the scope of

the thermal performance requirements, no comparison of standards is

possible.

Information from the data collected pertaining to the specific

areas listed above, in most cases, is insufficient in quantity to make

any thorough comparison between design practice and ASHRAE Parameters.

This is due mainly to the fact that the items mentioned above

generally are not covered by the existing building code, and

therefore, this information is not included with the submitted plans.

Although the data available has been small in volume, an analysis of

the ASHRAE 90-75 Section 9 power budget has been made for 1973 and

1977 data.

Data collected from plans is categorized into occupancies or tasks and separated by years as ^ check for noticeable trends in

lighting power usage (watts/ft. ) and type of light source,

fluorescent, incandescent or high intensity discharge (HID).

*Office buildings exhibit just the opposite phenomenon, with the

glass area decreasing as the heating degree days decrease.

228
The ASHRAE lighting power budget is an upper limit to the amount

of electrical energy available for lighting a proposed building. The

budget conforms to a set of criteria and calculations used only for

calculating a budget number and not for design purposes. Illumination

level criteria referenced by ASHRAE Standard 90-75 are those listed in

the Illuminating Engineering Society (lES) lighting handbook. The

budget is calculated assuming lamps of a given efficiency and

coefficient of utilization. The lighting power limit is calculated

from the formula:

WATTS

Where

CU X LE X .70

A Area in ft.^

FC Footcandle level

CU Coefficient of utilization

LE Lamp efficiency in Lumens/watt

.70 Light loss factor (accounts for dirt on the lamp and

walls, etc.)

The footcandle level is assigned by lES on a task area basis.

Task areas are areas where one specific task is performed. The areas surrounding task areas are called general areas and are 1/3 the

footcandle level of task areas but at least 20 footcandles.

Noncritical areas are areas where no specific task occurs and are 1/3

the footcandle level of general areas but at least 10 footcandles.

The total power budget consists of the sum of the power budgets for

those three areas. Most occupancies or tasks in the data base are considered by lES as a single task, as hallways and garages. Some

occupancies such as offices and classrooms are task lit and will

contain general and perhaps noncritical areas. Table 13 compares the

ASHRAE task area allotment with the lighting levels used in Wisconsin

for 1973 and 1977. It must be remembered that the ASHRAE value is for

task areas only and does not consider noncritical and general areas. The Wisconsin data contains all three lighting types.

There is considered to be no interaction between the lighting

systems and the HVAC system in Table 13. Natural lighting is assumed

not to contribute to the footcandle levels. The ASHRAE task area allotment appears to be high for several occupancies in comparison to

the Wisconsin data. This is undoubtedly because the data contains

noncritical and general areas, and the ASHRAE allotment is for task

areas only.

Another explanation for a rise in some lighting levels can be

found in the March 197A Lighting Systems Study published by the

General Services Administration, which states "Lighting levels in the

United States and elsewhere have generally been on the increase. In

this country, lighting levels in buildings such as office buildings

and schools have doubled in the past twenty years. This increase has

229
been facilitated by a more than corresponding increase in efficiency

of the lighting systems employed (i.e., incandescent to fluorescent),

coupled with a cost for energy that has remained relatively constant

over this period of time."

2 The average 1977 lighting power (W/ft. ) showed a drop of 7.4

percent from 1973 for the occupancies in common between the two years.

The lack of data keeps us from pinpointing the reason, although there

are several possible explanations: 1. Footcandle levels dropped.

2. Designers switched to more efficient lamps, as shown in Table 14.

3. Task lighting usage increased. The data does not reflect the

results of increased usage of switching and dimming circuitry which

possibly had a beneficial effect in reducing the wattage per square

foot in 1977. It appears that the use of more efficient lamps did

result in lower use of lighting energy, as efficient high intensity

discharge lamps became a sizeable percentage of the total indoor

lighting wattage in 1977.

The Arthur D. Little report indicates the effect of ASHRAE 90-75

on lighting in Table 15. This Table shows a reduction in lighting for

three occupancies and a total reduction of 24 percent for lamps and 22

percent for lighting fixtures. These figures can be loosely compared

to the 7.4 percent reduction in wattage per square foot from

Wisconsin's data. It would appear that the trend in lighting design

in Wisconsin is not as great as that obtained by implementing the

lighting power budget from ASHRAE 90-75.

A further impact of implementing ASHRAE 90-75, regarding HVAC

system capacities is shown in Table 16. The Arthur D. Little Company

claimed that heating equipment capacities would drop an average of 42

percent and that air-conditioning capacities would drop an average of

31 percent. These reductions are because ASHRAE specifies minimiim

equipment efficiencies and recommends ventilation values. The Arthur

D. Little percentages are compared to the overdesign values for

heating and air-conditioning equipment from Wisconsin's data for 1973

and 1977 in Table 24. This Table shows that the overdesign factors

increased from 1973 to 1977, while ASHRAE 90-75 can reduce system

capacities. These figures cannot be used on a straight comparison,

because the overdesign factor does not necessarily mean that the size

of the system capacities in Wisconsin increased. It must be

remembered that the overdesign factor is a ratio of system capacities

to total losses. Therefore, the total losses could be reduced while

the size of the specified HVAC equipment remains unchanged. This

phenomonen would produce an increase in the overdesign factor. This

increase can be thought of as a decrease in total losses of 40.3

percent for heating and a 53.1 percent decrease in heat gain for

air-conditioning. This would mean that the HVAC system capacities for

Wisconsin could decrease by the same value, which is in the same range

as the ASHRAE reductions.

In addition to the above mentioned areas governed by ASHRAE

Standard 90-75, ASHRAE includes guidelines that allow an equivalent

system analysis and for nondepleting energy sources. The equivalent

system analysis allows trade offs between components of the building

230
and equipment specifications as long as the total energy allowed by

the component method is not exceeded. Also, all energy from

nondepleting sources shall be excluded from the total energy

chargeable to the proposed alternative design.

CONCLUSIONS

The total connected load energy budget attempts to limit energy

consumption by limiting the connected load. It controls the output

capacity of the HVAC equipment and the lighting equipment, while

completely ignoring other energy consumers. By exempting makeup air,

this budget approach misses one of the largest energy consumers in

many buildings. This approach does not even consider the efficiencies

of such equipment. In limiting equipment output capacities, this

approach may be advocating energy inefficient equipment, as the more efficient equipment may have higher output capacities.

The total connected load is based on an energy allotment figure

that is adjusted for a particular building size and geometry. The

allotment figure and the criteria that the adjustment equations are based on have no actual building construction basis. The four

adjustment equations result in a progression of errors, as each

equation is dependent on the previous equation. This progress of

adjustments results in constants being varied by totally unrelated

items

.

The total connected energy load budget uses the lighting power in

the calculation of the total connected load. But there is no attempt

to limit or control the actual lighting levels. Other energy

consuming areas are also ignored by this approach.

In reviewing the thermal performance rule (13 Btu's per hour per

square foot) and ASHRAE 90-75, it is obvious that the ASHRAE Standard

encompasses many areas not governed by the thermal performance rule.

Of the areas the two approaches have in common, there are advantages

and disadvantages to each. The wide scope and comprehensiveness of the

ASHRAE 90-75 Standard makes it the preferred energy conservation

standard. Its range of energy related areas allows it to control

these areas and gives it the potential for the greatest energy

savings

.

It is recommended that ASHRAE 90-75 be used as a basis for a comprehensive energy conservation standard for the State of Wisconsin.

However, because some envelope component's characteristics for the

State of Wisconsin exceed those specified by the ASHRAE 90-75

Standard, new values consistent with Wisconsin's current practice

should be substituted for the ASHRAE values.

231
TABLE 1

TOTAL-CONNECTED LOAD ENERGY BUDGET

ADJUSTMENT EQUATIONS

AREA ADJUSTMENT: Ba = B + 3.6 50,000

A

NUMBER OF LEVELS: Bs = Ba (.77 + 0.23/n)

LEVEL HEIGHT: Bm = Bs (0.8 + 0.2h/14)

DEGREE DAY Bd = Bm + 0.0025 (DD-7500)

WHERE: A = Total Floor Area

B = Basic Energy Allotment

n = Number of Levels

h = Level Height

Bm = Energy Allotment as Adjusted for Height

Bs = Energy Allotment as Adjusted for Number

of Levels

Ba = Energy Allotment as Adjusted for Area

Bd = Final Energy Allotment

DD = Degree Days

232
THERMAL PERFORMANCE VALUES

FOR 1973 AND 1977 BUILDINGS

TABLE 2

OCCUPANCY NUMBER OF PLANS

MEAN THERMAL

PERFORMANCE VALUE PERCENTAGE

1973 19 / / CHANGE 1 n *7 o T O "7 "7

FACTORY/MACH . SHOP 38 13 21. 384 9. 008 -57.9

OFFICES 4 J iZ ZU . U Jz lU . ZZD -49.0

RETAIL ESTAB. 91 o8 zU

.

Id / o £ o o . bbz -57.0

WAREHOUSE O 1 oz Its . by/ Q R Q Q O . D J J -54.3

ARENA/ FIELD HOUSE J

1 "7 nnn 1 / . UUU b . UUU -64.7

CHURCHES 1 c \d J

"{ C "7 O Q lb . / J

J

/ . / D / -53.6

CLUB/LODGE Z Id . Uzy / . yuu -47.4

ENTERTAINMENT 11 z

1 / n "7 o 14. U/

J

9 . zUU -34.6

RESTAURANTS 22 D zl . 504 9 . 900 -54.0

ELEM. SCHOOL 8 13 . 425 o . 050 -40.0

APARTMENTS on . o j± y . ±3u -38.4

DORMITORIES 6 3 17.300 8.600 -50.3

MOTELS 10 1 13.000 8.500 -34.6

GARAGES 30 5 21.833 8.960 -59.0

REPAIR AREA 11 2 21.027 11.050 -47.4

VEHICLE SERVICE 30 6 20.823 11.180 -46.3

233
TOTAL LOSSES PER ENVELOPE AREA

FOR 1973 AND 1977 BUILDINGS

TABLE 3

OCCUPANCY NUMBER OF PLANS

TOTAL LOSSES PER

ENVELOPE AREA PERCENTAGE

1973 1977 1973 1977 CHANGE

FACTORY/MACH. SHOP 38 13 35.26 12.61 -64.2

OFFICES 43 12 34.70 22.30 -35,7

RETAIL ESTAB. 91 8 35.28 15.78 -55.3

WAREHOUSE 37 2 29.52 12.50 -57.7

ARENA/ FIELD HOUSE 3 2 33.60 11.90 -64.6

CHURCHES 15 3 40.09 10.22 -74.5

CLUB/LODGE 14 2 39.10 13.47 -65,6

ENTERTAINMENT 11 2 43.49 25.43 -41.5

RESTAURANTS 22 6 79.41 22.44 -71.7

ELEM. SCHOOL 8 4 31.19 22.93 -26.5

APARTMENTS 160 90 26.06 13.75 -47.2

DORMITORIES 6 3 28.05 17.29 -38.4

MOTELS 10 1 24.27 12.15 -49.9

GARAGES 30 5 41.84 11.62 -72.2

REPAIR AREAS 11 2 50.59 17.59 -65.2

VEHICLE SERVICE 30 6 44.77 16.29 -63.6

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241
TABLE 15

IMPACT OF ASHRAE 90 ON LIGHTING

Lamps Lighting Fixtures

(Percent) (Percent)

Office Buildings -28 -25

Retail Store -30 -25

School Building -15 -15

Average -2A -22

TABLE 16

IMPACT OF ASHRAE 90 ON HVA/C SYSTEMS

. Heating and Air Conditioning System Capacities Were Significantly

Reduced In All Buildings Investigated:

(PERCENT REDUCTION)

Heating Air-Conditioning

Single-Family Residence 23 18

Low-Rise Apartments 50 33

Office Building 32 35

Retail Store 48 27

School Building 57 40

Average 42 31

. Auxiliary HVA/C Equipment (Pumps, Cooling Towers, Supply Fans,

Etc.) Were Significantly Reduced. Also, Averaging 44% Less In

Their Rated Kilowatt or Horsepower Requirements

TABLE 17

IMPACT COMPARISON ON HVAC SYSTEMS

Wisconsin Over-Design Data

A. D. Little - 1973 1977 ASHRAE ChangePercent

Change

Heating 1.29 1.81 +40.3 -42

Air-Conditioning 1.43 2.19 +53.1 -31

242
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243
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250
REHABILITATION AS AN INSTRUMENT IN MEETING HOUSING NEED:

CAN IT REALLY WORK?

by

Jane Heron

Housing Programs Coordinator

Illinois Department of Local Government Affairs

Chicago, Illinois

There is an increasing trend in city planning toward rehabilitating

older buildings and conserving neighborhoods that might have become slums,

but the rehabilitation process is slow and unreliable. Few builders are interested in rehabilitation, most preferring new construction in the

suburbs. A major question is: can the rehabilitation process be changed

to attract more builders and become a high-volume business?

The suggested answer is that criteria to identify buildings needing

rehabilitation and to specify what repairs need to be made must be developed, using the cumulative knowledge of builders who have done such work

and the insight of people involved in building regulation. These criteria

should deal with the fundamental structural and safety characteristics of

buildings, to provide a yardstick for selecting the right buildings and

deciding how much work is required.

Key Words: Decision criteria; demolition; housing needs; physical condition

rehabilitation.

251
INTRODUCTION

Housing costs have risen dramatically in the past few years, as we

all know. The average cost of new homes is over $50,000; in 1970, the

F.H.A. ceiling was $33,000 against today's $55,000. This kind of inflation has two consequences for the housing market. First, it stimulates

demand for older buildings that are less expensive than new ones. Second,

it puts more households into the "housing-poor" category, forcing them

to spend too much income on housing or live in crowded or otherwise

inadequate conditions. In today's market, even middle-class families

are feeling the squeeze.

This situation has produced a growing market for older residential

properties that calls for vastly improved rehabilitation techniques.

Yet at present we lack even a method of assessing the magnitude of the

problem, because we lack criteria for identifying dwellings that can

and should be rehabilitated. Measuring housing need has historically

been the business of sanitation specialists, social workers, and

planners and economists working in government. The building industry

has focused on supplying the buildings, once need is defined and incentive programs are in place. The result of this separation is the

absence of any uniform standard of adequate physical condition for

older buildings.

Many criteria have been tried by the Bureau of Census over the years,

but each has been unsatisfactory in one way or another. Currently, HUD's

criterion for adequate living conditions is that the dwelling contain

complete plumbing, afford one room per person, and cost no more than 25%

of household income. For owners, a building built before 1939 and valued

under $10,000 is deemed inadequate. Specific physical condition of the

dwelling, however, is left out. Our studies of housing need in Illinois

indicate that this standard underestimates housing need by 30 to 50 percent,

possibly 400,000 households. Much of this need can and should be met

through rehabilitation. Low-income households cannot afford new construction;

many are elderly owners who do not want to move. With the high cost of land

and energy, higher income young households are also being attracted to older

buildings.

The potential for a vast market is there, but the market can only be

tapped once we have the means to measure the need and identify the buildings.

The burden of this paper is to suggest that the industry, and the regulatory

sector in particular, must become involved in developing the standards that

identify buildings needing rehabilitation, to further its own interests and

also to play its role in meeting the country's housing needs and preserving

our cities and towns as good places to work and live.

252
MUST OLD BUILDINGS DIE OR ELSE JUST FADE AWAY?

One-third of the occupied dwellings in the United States were built

before 1939, and 51% of them are occupied by renters. The rental buildings

particularly are likely to need substantial rehabilitation, since landlords

frequently defer maintenance and repairs. Where ill-maintained older

buildings are located, neighborhoods gradually deteriorate and become slums.

People who can afford it move farther and farther out to the suburbs, leaving

behind the old neighborhoods, the old buildings, and the people who cannot

compete in the broader marketplace. Such neighborhoods are like a cancer within the larger community; eventually the entire city is seen as an inhospitable place to live. Factories and offices then relocate to the suburbs,

leaving the city's vast capital facilities and investments underutilized

and financially overburdened. In short, in the absence of effective rehabilitation, whole cities may die.

One historical cure for older buildings is the bulldozer. Vast numbers

of older buildings were demolished between 1950 and 1970, through urban renewal

programs that emphasized slum clearance. Conservation and rehabilitation were

among the tools in the renewal kit, but they were used rarely and discussed

seldom because clearance was the vogue. Clearance paved the way for largescale redevelopment and new construction — more visible, more immediately

profitable and less trouble than remodeling and repairs. Peace to the people

who were "urban removed."

In the past five years, while housing costs and interest rates rose out

of sight, rehabilitation has become a major focus of housing and community

development programs. Where new construction was seen as the answer to our housing problems just ten years ago, rehabilitation seems to be taking its

place. From neighborhood organizations to Congress and HUD, the word is out: save our neighborhoods; preserve old buildings; no more demolition, we shall

not be moved I HUD now requires all cities applying for community development

funds to identify all dwellings "suitable for rehabilitation," notwithstanding

the lack of criteria.

This sudden interest in rehabilitation is not so much a new respect for

old buildings but a reaction to the cost of land, construction, and energy.

It appears that the need to maintain and restore older residential neighborhoods will become a permanent part of public programs and private investment.

Yet the cost of rehabilitation remains high, cost estimates are repeatedly

low, and the construction and lending industries continue to be wary. Rehabilitation is largely the business of small contractors who handle a few

buildings and often fail to serve the owners' best interests. The owners

feel plagued by unreasonable code requirements and ineffectual job specifications and cost estimates.

253
Clearly something is amiss. Even if rehabilitation must be costly

because of the problems likely to be found behind old walls, the cost

of new construction should by now have eliminated the question "Is it

worth it?" and substituted the question "How can it be made more worthwhile?"

On this question, the building industry are the experts.

TO REHAB OR NOT TO REHAB: HOW TO DECIDE?

Having approached a critical point in terms of high cost, perhaps we

are on the verge of tackling the problem. One facet of the challenge is

to identify the symptoms of the disease called deterioration and develop

the criteria for deciding when minor surgery, or rehabilitation, is appropriate and when radical surgery — demolition — is required. These

decision criteria operate on two levels. One is the national level, where

we presently lack the criteria to estimate the total need and cost of undertaking rehabilitation where it is feasible. The other is the local level

where we lack the systematic criteria to identify which buildings to rehabilitate; we select almost at random or oil the wheel that squeaks loudest.

Efforts have been made to develop these criteria, but a few examples

illustrate the difficulty of the problem. The U.S. Bureau of Census has

wrestled with the issue of identifying inadequate housing for 40 years and

failed to come up with a satisfactory set of criteria. The one criterion

which has persisted since 1940 is the absence of complete plumbing. On

three occasions, however, the plumbing facilities specified to constitute

"complete" plumbing have been changed. At the same time, with the extension

of public water and sewer systems following World War II, incomplete plumbing

has become almost statistically insignificant, found today in less than four

percent of all dwellings.

From 1940 through 1960, enumerators were asked to identify variously

dwellings needing major repair, or dilapidated buildings, or deteriorating

buildings. Owing to the subjectivity of the enumerators and geographic

differences, the results were inconsistent and the findings were harshly

criticized. The new result was the omission of physical condition questions

in the 1970 Census. One new inferential criterion was developed in a special

tabulation prepared by the Census Bureau for HUD in 1974; the age-to-value

relationship for owner-occupied single-family dwellings. A single-family

home built before 1939 and valued at less than $10,000 in urban areas, or less than $7,500 in rural areas, was deemed inadequate. This criterion,

unfortunately, is just as subjective as those used in earlier years, because

the owner completed the questionnaire and may easily have understated or over-rated the value of the property. It is also of little use in rural

areas where frequently there is no market and decent homes may sell for

$5,000.

For the 1980 Census, the Bureau's housing advisory panel has thus far

considered six factors and rejected three.

254
1) The presence of rodents, rejected because rodents are common

in less developed areas and field mice in suburban homes are

not the issue.

2) Bedrooms used as passageways, rejected because of probable

misunderstanding and resentment among respondents and the

possibility that all bedrooms with connecting doors to bathrooms might be counted.

3) Holes in floors or ceilings.

4) Crumbling plaster or peeling paint.

5) Holes in the roof, rejected on the grounds that it duplicated

the above. In 1980, homes with roof and attic damage will not

be identified, so long as the ceiling below is all right.

6) Whether or not there is a home improvement loan outstanding on

the property — regardless whether the loan is for a new patio or major repairs.

My intention is not to ridicule the panel wrestling with these questions.

Rather, it is to show the difficulty of coming up with apt questions. More

important, such criteria will not enable us to identify dwellings to demolish or those to preserve. If, in fact, rehabilitation can be successful

in conserving basically good dwellings (and commercial buildings too) , the

magnitude of the problem and its geographic locations must be determined,

in order to decide how much money is needed and where. Once this question

is answered, a market can emerge and the construction industry move in.

Now the scene shifts to the local level. Even if we can competently

assess rehabilitation need at the national level, we lack a system for

deciding which buildings to rehabilitate when and how much to invest, and

political decisions of one sort or another prevail. Indeed it appears at

present that considerable sums of federal community development and

weatherization money are being spent on band-aid and cosmetic repairs to

very old, insubstantial dwellings which may remain in use just enough longer,

because of these renovations, to become genuinely dangerous to life and

health and to trigger or perpetuate the problem of neighborhood and community

decay. In addition to criteria for when to rehabilitate and when to demolish, we need systematic criteria for determining what work must be done.

HOW MUCH REHAB IS ENOUGH?

The crux of the problem is to define a standard of adequacy and develop

a sliding scale of physical condition for older buildings; for example, from

"needing minor repairs" to "requiring demolition" —quantitative criteria by

255
/ which buildings could be rated numerically. Some efforts have been made to

design such a system, but none is widely used. A major problem is identifying the cutoff at which rehabilitation is not economical or appropriate. A

related problem is that our codes often seem to require too much, driving

costs up, rather than relating improvements to existing defects. A sliding

scale would quantify defects in the building and rank them, giving greater

weight to structural defects or immediate safety hazards. A building with

too many points or too many immediate safety hazards would qualify for

demolition. Rehabilitation would be indicated by scores within a lower

range. Neighborhoods needing systematic housing code enforcement for minor

repairs would fall into the lowest category. A major asset of this type of

system is that it provides the defining characteristics of "buildings suitable

for rehabilitation" and identifies precisely the work which must be done to

rehabilitate a given building.

It may seem that codes do this job, but that is not the case. The codes

contain all the requirements new buildings should meet, but some of them are inapplicable to older buildings because of difference in construction. In

any case, the codes as we know them cannot directly be used to identify what

is missing or what needs correction in a deteriorated old building. Nor can

the codes be used to rate deficiencies by degree of hazard or rank buildings ' on a sliding scale. The code is not a policy tool, and these are policy

decisions.

The codes in a sense, are part of the problem. For example, the codes

state that the entire building shall meet the code when alterations valued

at 50% or more of replacement cost are undertaken. Obviously this increases i total rehabilitation cost. Perhaps not quite as obvious is the arbitrariness | of this criterion. Surely it is the actual condition of the building, not | the cost of alterations, that warrants spending the money to bring it up to I code. A rating system that quantifies defects would provide a more reasonable j basis for this decision. !

] On the other hand, if the 50% rule is removed from the code, the building ! department has no means of knowing what rules, that is, what code to apply. , Where does the housing code stop and the building code begin? The answers 1 to this question equally lie in the development of decision criteria based i on experience to identify those conditions which must be corrected and those I which may, while also affording some flexibility about the method of correction.!

It is not intuitively obvious that every feature of a building constructed in ! 1875 must comply with today's accepted standards — which differ from those \ of only 20 years ago — in order to afford safety and comfort to the occupants.

One argument frequently used against rehabilitation as a major tool in

meeting housing needs is that each building is an individual case with its own problems which make the cost of time and materials totally unpredictable.

This belief has also kept most builders out of the business and left the work

to small short-lived firms. However, in the twelve years since the 1965 HUD

256
Act introduced the rehabilitation loan program, several thousand dwellings

of various types and sizes have been rehabilitated all over the country.

By now enough experience has been logged to enable us to discover what

types of hazards are most common, what kinds of repairs and new installations are most often needed, and what problems are most frequently encountered during rehabilitation in various types of construction. This kind of

information could be the basis for a system to identify buildings needing

and suitable for rehabilitation, and the cumulative experience could provide

a more efficient approach to rehabilitation which would open the door to

high-volume construction work.

This is not a plea for "softness" or unsound decisions which jeopardize

the inhabitants of buildings and the inspectors who determine compliance with

codes. On the contrary, it is a plea for hard criteria based on actual con- struction experience to systematize the process of rehabilitation, from

identification of suitable buildings to prompt completion of the work. This

will enable us to rehabilitate more buildings faster and to eliminate those

buildings harmful to occupants and communities more readily. If building

regulation places emphasis on maintaining the quality of existing housing,

it will make building maintenance and renovation a major component of the

construction industry.

257
/
THE NATIONAL FIRE INCIDENT REPORTING SYSTEM:

SOME USES OF FIRE LOSS DATA

by

Henry Tovey, Director of Planning

National Fire Prevention and Control Administration

Washington, D.C.

The National Fire Data Center of the National Fire Prevention and

Control Administration is directed by law to collect, analyze, and

disseminate data on the occurrence, control, and results of fires of

all types. One of the major objectives of this activity is to provide

the building code community with information it needs for writing and

updating building codes so that they provide as much protection at as low a cost as possible. The fire experience data collected by the

National Fire Incident Reporting System of the Center has a high potential utility for that purpose. However, the initial data collected

need significant improvement in completeness and accuracy. This paper

describes the basic design of the National Fire Incident Reporting

System, and illustrates several ways in which the data collected by the

system can be used to identify and rank fire hazards associated with

building structures. The current status of the system, including

efforts to validate the data, are described.

Key Words: Building codes; data collection; fire hazards; fire protection;

National Fire Data Center; regulation; reporting system;

scenarios; system design.

259
INTRODUCTION

In the United States fire is a major national problem. The

National Commission on Fire Prevention and Control pointed out that

the United States leads all major industrialized countries in per

capita deaths and property loss from fire.

Acting on the recommendation of the Commission, the Congress

passed and the President signed the Federal Fire Prevention and Control

Act in 1974. The Act dealt with the entire national fire problem and

it established the National Fire Prevention and Control Administration

(NFPCA) . It also assigned Federal-level responsibility for the collection, analysis, and dissemination of data on the occurrence, control,

and results of fires of all types to the National Fire Data Center of

the Administration. The legislative mandate specified that the program

of the Data Center shall be designed to provide an accurate nationwide

analysis of the fire problem, identify major problem areas, assist in

setting priorities, determine possible solutions to problems, and

monitor the progress of efforts to reduce fire losses.

This presentation describes the National Fire Incident Reporting

System (NFIRS) , a major ongoing effort undertaken in partial fulfillment of this mandate. It provides a very brief review of the basic

concepts that shaped the design of the system, gives a report on its

current status, and illustrates how it can be used to improve our understanding of the fire problem and thus, help make the building regulatory

process more rational and cost-effective.

THE NFIRS DESIGN

The primary function of the National Fire Incident Reporting

System is the collection of comprehensive national statistics on fires

attended by the fire service. However, NFIRS is more than a tool for

data collection. It provides assistance in the development of state,

regional, municipal, and local fire data systems, and in the standardization of fire data reporting on all levels to help these jurisdictions

in doing their jobs.

NFIRS is a national fire data network. It is based on the cooperation

of local, regional, and state fire jurisdictions, and the NFPCA. The

Data Center developed a training manual for use by instructors to train

firefighters at the local level to collect data; a handbook for those

who complete the forms; and a computer software package for processing

the data. These materials and technical assistance by the Center staff

are provided free of charge to participating jurisdictions. In addition,

a "first year" grant of up to $20,000 and a small "second year" grant

can be obtained by a state joining the network to partially off-set the

initial costs of training, quality control, and data processing.

260
In the NFIRS network, local fire departments collect data on each

incident they attend. Fire incident reports are sent to the appropriate

state-level authority, generally the office of the state fire marshal,

where they are processed onto computer tape. The data can also be processed at the local or regional level and then passed on to the state

jurisdiction in computer tape form. The collected fire data are tabulated and analyzed and used by the state or municipality to produce

annual and periodic reports to develop feedback reports to the participating fire departments and to analyze special problems. A copy of

the computer tape with the fire incident data which has been processed

at the state level with the standard NFIRS software package is sent to the National Fire Data Center. The Center analyzes the received data

and prepares reports for feedback to the participating state sources

as well as for dissemination to the fire protection community, government executives, and legislators, and such other interested groups as those concerned with building codes.

CURRENT STATUS OF NFIRS

At the present time, 18 states, Alaska, Delaware, Illinois, Iowa,

Maine, Maryland, Michigan, Minnesota, Missouri, Montana, New York, Ohio,

Oregon, Rhode Island, South Dakota, Utah, West Virginia, and Wisconsin

participate in the system. The great majority of these states are just

beginning, however, and Ohio is the only one for which we have a full

year's data. We also have data from California which is not officially

an NFIRS state but which has been operating a very similar fire data

system for a few years. The Center plans to expand NFIRS to 21 states

in 1978 and 34 states in 1979. We hope that, ultimately, all states

in the Union will participate.

THE REPORTING FORM

The uniform classification for data reporting adopted by NFIRS

was developed by the Nation's fire community through the voluntary

consensus mechanism of the National Fire Protection Associations '

s

Committee 901 on Fire Reporting. All data elements collected by NFIRS

are based on this classification. They are all included in the incident

and casualty report forms developed by the 901 Committee and adopted by

NFIRS

.

However, NFIRS does not require the use of any specified forms.

Each participating jurisdiction is free to design its own as long as

the data elements are based on the uniform classification scheme and

the form includes the data elements that are being collected nationally.

For example, Ohio, the first NFIRS state, uses what we call Layout 1 forms which were the official NFPA 901 forms in 1975. Figure 1 shows

the incident report form and Figure 2 the casualty report form. States

that joined NFIRS in 1977 use the Layout 2 forms, shown on Figures 3 and 4. Layout 1 and Layout 2 contain the same data elements and differ

only in the way these data elements are arranged. The Fire Data Center

has developed NFIRS software packages for processing data on these forms.

261
WHO. WHERE, AND WHEN . The NFIRS fire incident reporting forms are made up of blocks of data elements. The logic behind this arrangement is that for certain incidents it is necessary to record only a certain set of facts. The first block on Layout 1 form, which I will

discuss here because I will be using Ohio data, contains the set of

elements that is reported for even the simplest incident. These elements

give the incident a unique ID and record the who, where, and when. They

also provide information of importance to fire department management

such as the number of fire service personnel, engines, aerial apparatus,

and other vehicles used at the scene.

But while the NFIRS form has spaces to record all these data elements,

NFIRS does not collect data on all of them. Collecting names of occupants

would be of little value for national level analysis and could lead to

problems under the Privacy Act. NFIRS does, however, collect the zip

code and census tract data. Both of these constitute bridges which will

permit relating fire incident data to demographic and other data organized by census tract. This may make it possible to investigate the

relationship between demographic and socio-economic factors and the fire

problem. Unfortunately, zip code and consus tract are among the data

elements which are often not recorded properly. This may be because

they are not known to the people who fill out the forms but perhaps

also because their usefulness is not obvious. We hope that once meaningful analyses based on combining NFIRS and census tract data come

out, this situation will change.

The utility of the other elements in the first block of the form

is apparent. For example, plotting the number of incidents against

the time of alarm, or day of the week, can indicate the existence of

patterns that can be used to establish cost-effective staffing levels

in fire stations. Data received from Ohio for 1976 show that the

number of alarms is lowest at about 5:00 a.m., rises to a peak at the

early afternoon, and then drops again (Figure 5). The day of the week,

on the other hand, seems to have no effect (Figure 6).

STRUCTURE AND OCCUPANCY . Information on the place where the fire

happened is provided by a series of questions in the second block on

the form, lines H, I, and J. They deal with the type of structure in

which the fire occurred, the construction type and method, and the use

to which the property was put at the time of the fire. Data derived

from answers to the first of these questions permits the analysis of

fire incidence statistics in terms of the type of structures involved,

such as buildings, tents, bridges, or underground structures.

Ten different categories of structure type can be coded and

tabulating data by these categories makes it possible, for example,

to identify what type of structure is associated with the greatest

dollar loss (Table 1) . Such information makes it possible to focus

prevention programs where they are most needed. Information on fixed

property use allows analysis of the fire problem by type of occupancy

one of the most popular ways of analyzing fire data. Table 2, for

example, shows "where fire deaths occur" by fixed property use. It

is obvious from that table that residential fires deserve much of our attention. Different occupancies may be required to provide different

262
levels of safety, and many codes are directed at problems presented in

terms of a particular type of occupancy. Comparisons of the fire ex- perience of structures with different fixed property uses can be used

in monitoring the effectiveness of codes and regulations and suggesting

appropriate revisions. The rational way of deciding how to revise these

codes and regulations, and how to decide which should be revised first,

is on the basis of fire hazard associated with each occupancy type.

These hazards can be identified and quantified by fire experience data.

Information on construction type permits analysis in terms of

standard constructions that differ in fire resistance and stability

under fire conditions, such as fire resistive structure, heavy timber,

or unprotected wood frame. The terminology used in the system is

based on an NFPA Standard (Table 3) which can be related to the several

building codes in use in the United States such as the Basic Building

Code, Standard Building Code, and the Uniform Building Code. For example, the NFIRS fire resistive category includes Basic Building Code

Type lA and IB; Standard Building Code Type I; and Uniform Building

Code Type I. Heavy timber includes BBC Type 3A; SBC Type III; UBC

Type III (HT) . This indicates that data collected by NFIRS can be

used to investigate the relationship between construction type and

actual fire loss experience and thus, help to identify ineffective

codes and point out needed improvements.

Using the 1976 Ohio data of over 67,000 reported incidents, and

selecting only residential fires, it appears that unprotected wood

frame constructions had by far more fires than any other construction

type (Table 4) . These fires also show the highest cumulative dollar

loss. This is not unexpected since most single family dwellings are

of this type, and these data show totals, not rates. The National

Fire Incident Reporting System does not collect data on how many

buildings of what construction type there are in the reporting districts,

and on what building codes are in force, so that fire risks associated

with the different construction types and different codes cannot be

established. NFIRS can provide a part of the answer but it is nec- essary to combine NFIRS data with data based on some kind of a prefire inventory of property at risk before relative fire risks for

the various construction types can be established.

Data on methods of construction is meant to help in identifying

differences that may exist between the behavior in fire of structures

built on the site and those built in a factory in a modular form or assembled on the site. There are four major categories of construction

methods (Table 5) . Ohio data on this element indicate that most losses

are associated with site-built structures (Table 6) . Again, this is

not unexpected since such structures dominate the field. We need information on how many buildings constructed by the different methods

are "at risk" before we can say anything about the relative safety of

these methods.

CAUSAL FACTORS . The third block of data elements on the NFIRS

form, lines K and L, deal with the causes of fire. The form asks

about equipment involved and lists four major types of causal factors

because from a technical point of view fire does not have a single

cause. To know how the fire started, we need to know the form of heat

of ignition; the type of material first ignited; the form of material

263
first ignited; and the ignition factor. The question concerned with

whether the ignition source was a ^piece of equipment is of vital importance to equipment manufacturers as well as to such regulatory

agencies as the Consumer Product Safety Commission because it identifies equipment and products that require further attention. For this

reason, if it is a piece of equipment that was involved in ignition,

further questions are asked about it on line T of the form — the

make, year, model, serial number, and voltage.

The other questions in this block ask about the form of the

ignition energy (Table 7), the type of material first ignited (Table

8), the form or use (Table 9) of the first item ignited, and the ignition factor (Table 10). The ignition factor is the action or lack

of action that permitted the heat from the ignition source to cause

the ignition of the first item. The Ohio data shows that the most

important ignition factor in terms of loss of life is "misuse of heat

of ignition" which includes the leaving of a smoking material

unattended (Table 11)

FIRE GROWTH . Information on fire growth is provided by the

questions in the fourth block on the form, lines M, N, and 0. It

is made up of several components and like the information on causal

factors, it is most useful when these components are related to each

other and to other information about the fire. One component is con- cerned with the extent of the spread — was the flame damage confined

to the object of origin? to the room of origin? to the floor? did it

extend beyond the building or origin? (Table 12). Obviously, this information in itself has a limited value. But if a high correlation

were found between extent of flame damage and, say, polyurethane as the type of material first ignited, this would have important implications concerning the fire hazard of polyurethane products.

The second component of the fire growth complex is concerned with

what helped it most to grow. After all, it is not always the first

item ignited that is the important factor in fire spread. It could

have been the second or even the third item ignited — the drapery

that spread the fire across the room in no time at all but was ignited

from a small wastebasket fire started by a glowing match. The third

component is concerned with the path taken by the spreading fire —

did it move up an open staircase? did it spread across a long hall

without fire doors? or did it move through a hole in a fire wall?

Inferences that can be drawn from data on these points would be of

much value to those concerned with life safety codes and to architects,

builders, or makers of furniture and furnishings. For this reason, the

system provides for recording and collection of the data on NFIRS forms.

However, the collecting of information on these two aspects of fire

growth is a relatively new development in fire reporting, and during

the initial stages, NFIRS does not collect it on the national level.

DETECTORS, SPRINKLERS, AND DOLLAR LOSS . The fifth block on the

form, lines P, Q, and R, include questions concerning detector and

sprinkler performance, and data on these points would also be of much

264
value to those responsible for building codes (Table 13) . Unfortunately,

the NFIRS data available at this time has so few cases where detectors

were present and operating that no statistically significant differences

in deaths, injuries, and losses could be established between these cases

and those where detectors were not present. As more smoke detectors

come into use, and the NFIRS data base grows, we expect that such

information will become available.

There is more data regarding the value of sprinklers. The data

in Table 14 indicates that average loss is significantly less where

automatic sprinklers are installed and operating properly than where

there are no sprinklers.

The fifth block on the form also asks about dollar losses resulting

from the fire. The dollar loss is, o^^ course, of major importance to

the owner of the burned property. It is also very important in determining priorities for, and determining the cost-effectiveness of programs aimed at combating the fire problem. Unfortunately, reliable

dollar loss data are hard to come by because fire service personnel are not schooled appraisers. The multitude of methods for loss estimates — original cost, market value, replacement cost — is another obstacle

to obtaining comparable data. Since information on total dollar loss

is so important, both a dollar estimate and a range are asked for on

line Q of the form. The instructions explicitly request that the

estimates be made on the basis of cost of replacement in like kind

and quality, and that only the direct physical loss — to the structure, contents, machinery, equipment, and such, be considered. Table

15 shows that residential and non-residential structural fires account

for about the same dollar loss, approximately A3% of the total, even

though there were more than twice as many residential as non-residential

fires

.

CASUALTIES . The identification and characterization of casualties

resulting from a fire has always been an integral part of fire reporting.

NFIRS collects information on fire casualties on a separate casualty

report (Figure 2) which calls for information on the victim's age and

sex, affiliation, casualty type, and whether it was an injury or death.

Other questions such as those concerning the nature of the injury, part

of body injured, and disposition, or those concerning familiarity with

structure and conditions preventing escape are designed to provide

additional information about fire casualties. Such additional information is meant for analysis and correlation with the various fire incident parameters. For example, if the data show that lack of familiarity

with structure is an important factor, an educational campaign to get

people familiar with the structures in which they live and work would

seem indicated. However, if correlation with incident data shows that

lack of familiarity with structure is of importance only for certain

types of occupancies such campaigns could be aimed more precisely and

thus, be both more effective and more cost effective.

FIRE SCENARIOS . This ability to correlate one set of data

elements against another, and thus to discover a trend, for example,

is a major strength of the National Fire Incident Reporting System.

The system also makes it possible to use another analytical technique

265
for ranking fire hazards and evaluating different intervention strategies

called the "fire scenario." A fire scenario describes the chain of

events leading up to the fire. In the scenarios prepared at the Data

Center, we are using the following attributes of a fire:

1. Fixed property use

2. Time of day

3. Form of material of ignition

4. Type of material ignited

5. Form of material ignited

6. Ignition factor

The Data Center has developed computer programs which query NFIRS

data for combinations of these factors and print out those that occur most frequently. Such a computer printout, based on the 1976 Ohio data

in the data base, is illustrated on Table 16. It shows that the most

frequent scenario for residential fires is a cigarette left burning on

a sofa while the smoker falls asleep, perhaps never to awaken. This

scenario, incidentally, is believed to be responsible for over 50% of

all deaths resulting from residential fires.

Once the most frequent fire scenarios are identified, the next

step is to develop the most cost-effective intervention strategies.

This is a difficult process because accurate valid data necessary to

compare the outcomes of alternative strategies are often not available.

In spite of these difficulties, however, the fire scenario technique

is a promising tool for planning fire prevention and control programs.

We expect that as NFIRS expands and the accuracy of its data improves,

it will provide some of the necessary data.

CONCLUSION

This discussion of the National Fire Incident Reporting System

has indicated what it can, and will, provide to help building code

organizations to make more rational, cost-effective decisions. We

would appreciate your comments and would welcome your suggestions for

making the system more useful.

266
. Fire Department

Fill In This Report

In Your Own Words

902F 6/77 LAYOUT I (ANY STATE) INCIDENT REPORT 1 Delete

2 Change

1

""FD ID ''Incid

1

ent No.

1 1 1

'Exp. No.

1

IVlo.

1

''Day "Vear

1

^ Day of the Week 'Alarm Time _1 1 1

Time—

"In Service" III

CORRECT ADDRESS; No. Dir. Name

1 1 1 1 1 1 1 1 1 1 1

Type r1Zip Code

1 1 1 l _ _L

^ Census Tract

i I J 11

Occupant Name Telephone Room or Apt.

Owner Name Address Telephone

'^Method of Alarm from Public

1

^Type of Situation Found

1 . Type of Action Taken

1

Co. Inspection

District

,

1 1 1

Shift No. Alarms ^ Mutual Aid

1 DRec'd 2 0 Given

No. Fire Service Personnel Used at Scene

|

No. Engines Used at Scene i . No. Aerial Apparatus Used at Scene |

| j

No. Other Vehicles Used at Scene | .

2

^ No. Incident-related Injuries* ^ No. Incident-related Fatalities* ^ Structure Type

Fire Service | | | | Others |

| | Fire Service |

| | | Others |

1 1

1 Fixed Property Use

^Area of Fire Origin L_L

^Uevel of Fire Origin

Complex Mobile Property Type*

Construction Type rconstruction Method

K ^Equipment involved in Ignition (if any) *

*

1 .

^Forrr1 of Heat of Ignition

1 1 1

L ^Type of Material Ignited

1

'

^ Form of Material Ignited 1^

^ Ignition Factor I lJ

^Extent of Flame Damage

, L

IF FLAME SPREAD Type of Material Generating Most Flame BEYOND ROOM , OFORIGIN; | |

Avenue of Flame Travel

1 1 Extent of Smoke Damage

1

1 F SMOKE SPREAD Type of Material Generating Most Smoke BEYOND ROOM , OFORIGIN; |

|

Avenue of Smoke Travel

1 ' Extent of Water Damage ^ Extent of Fire Control Damage

1

^ Termination Stage

1

oo

0 m

3) —

o

1 30m

Time from Alarm to Agent Application

1

Method of Extinguishment ^ Detector Performance

1 Estimated Total

Dollar Loss i i

1 1 1 1 1 1 II

^ Property Damage Classification

1

^ Sprinkler Performance

1 Officer In Charge (Name, Position, Assignment) Date

'List name, age, sex, and description of injury

for each casualty on form 902G.

R

Member Making Report (If Different from Above) Date 02

•• Complete Line S and/or T Q Check box if remarks are made on reverse side.

3

'^If Mobile Property 1 Year 1 Make 1 Model 1 Serial No. 1 License No. (If any) \

4

p» If Equipment Involved

in Ignition

1 Year

i

1 Make

i

1 Model

i

1 Serial No.

i

1 Voltage (If any) 1

Figure 1
-Fire Department

Fill In This Report

In Your Own Words (ANY STATE) CASUALTY REPORT 902G 6/77 LAYOUT I A FD ID ' Incident No. 'Exp. ""Mo. roay 'Year ' Day of Week r Alarm Timefc nf 5

1 1 1 1 1 No.1 1

Casualty Number L_LJ

1 Delete 2 D Change

Casualty Last Name First Name Ml D.O.B. 'Age

1

Time of

Injury

1 1 1 Home Address Telephone

^ SEX CASUALTY TYPE SEVERITY AFFILIATION

1 Male 1 Fire Casualty 1 Injury 1 Fire Service 2 D Female 2 Action Casualty 2 D Death 2 Other Emergency Personnel 3 EMS Casualty 3 Civilian ^Familiarity With Structure

, L

^Location at Ignition

1

^ Condition Before Injury

1 ^ Conditions Preventing Escape

, L

Activity at Time of Injury ^ Cause of Injury

, L_ ^ Nature of Injury

1

^Part of Body Injured

1

^ Disposition

1

w

see Remarks on Back OSee Additional Report

^ Casualty Number i

1 l_l

1 Delete

2 Change

Injury

I ' ' Home Address

' six

1 Male

2 Female

Telephone

CASUALTY TYPE

1 dl Fire Casualty 2 Action Casualty 3 EMS Casualty r

SEVERITY

1 CH Injury 2 Death

AFFILIATION

1 D Fire Service

2 Dother Emergency Personnel 3 Civilian Familiarity With Structure

^ Conditions Preventing Escape

Location at Ignition

^ Activity at Time of Injury

Condition Before Injcry

^Cause of Injury

Nature of injury ^ Part of Body Injured ^Disposition

see Remarks on Back see Additional Report

' Casualty Number

1 1 1

1 Delete

2 Change

Casualty Last Name Age Time of

Injury

' I I Home Address Telephone

SEX

1 Male

2 Female

CASUALTY TYPE

1 Fire Casualty 2^ Action Casualty 3 EMS Casualty

SEVERITY

1 Injury 2 Death

AFFILIATION

1 Fire Service 2^ Other Emergency Personnel 3D Civilian Familiarity With Structure

''Conditions Preventing Escape

^Nature of Injury

Location at Ignition Condition Before Injury

' Activity at Time of Injury ^Cause of Injury

Part of Body Injured ^Disposition 1

See Remarks on Back See Additional Report

Officer in Charge (Name, Position, Assignment)

Member Making Report (If Different From Above)

Figureg2
Fill In This Report

In Your Own Words (ANY STATE) INCIDENT REPORT

Fire Department 902F 6/77 LAYOUT 2

1 Delete 2 D Change

Incident No.

I I I I 1

Mo.

I

Day

I

Year

I

Day of the Week Alarm Tin _l I L J L

CORRECT ADDRESS No. Dir. Name Type

I I I I I I I I I I I I I I I I

I

I I I

Zip Code _LJ \ LCensus Tract

J \ \ I L

Occupant Name Room or Apt.

Owner Name Telephone

Method of Alarm from Public

^ype of Action Taken

Type of Situation Found

No. Alarms j Mutual

I 1 Rec'd

Co. Inspection

District i

I L_

Aid2DGj.

No. Fire Service Personnel Used at Scene J L

No. Engines Used at Scene J L

No. Aerial Apparatus Used as Scene

I I I

No. Other Vehicle Used as Scene

2

^o. Incident-related injuries^

Fire Service 1

1 1 1 Others |

j {

No. Incident-related Fatalities Fire Service 1 1 I I Others |

| |

Complex

1 1 Fixed Property Use

1 1 1

Mobile Property Type'^

"Area of Fire Origin

1 1

Level of Fire Origin

1

r Termination Stage

'Equipment Involved in Ignition (if any)^

1 1

^ Form of Heat of Ignition

1

1 'Type of Material Ignited

1 1

^Form of Material Ignited

1 1

^ Ignition Factor

1 1

M

Structure Type

r Construction Type

' Construction Method

N

'Extent of Flame Damage Extent of Smoke Damage Extent of Water Damage

0

"Extent of Fire Control Damage

1

^ Detector Performance

1

^ Sprinkler Performance

P

IF FLAME SPREAD Type of Material Generating Most Flame BEYOND ROOM

OF ORIGIN 1 1

Avenue of Flame Travel

Q

IF SMOKE SPREAD Type of Material Generating Most Smoke BEYOND ROOM

OF ORIGIN 1

1

Avenue of Smoke Travel

Method of Extinguishment

wEstimated Total

Dollar Loss 1

|

1 1 1 1 1 1 1 I

^ Property Damage Classification

1

Time from Alarm to Agent Application

List name, age, sex, and description of injury

for each casualty on form 902G

Complete Below

Member Making Report (If Different from Above)

ED Check box if remarks are made on reverse side.

u 3

If Mobile Property 1 Year 1 Make 1 Model 1 Serial No. ' License No. (if any)

V 4

Equipment Involved

In Ignition

j Year

i

1 Make

i

^ Model

i

^ Serial No.

i

^ Voltage (if any)

i

Figure 3

269
I

Fill In This Report

In Your Own Words (ANY STATE) CASUALTY REPORT

.Fire Department

r r r

' r 1 f -—

'^FDID Incident No. Exp. Mo. Day Year Day of Week Alarm Time 5

1 1 1 1 1 No.1 1 1 1

902G 6/77 LAYOUT 2

Page

of

^ Casualty Number 1

1 1 1

1 Delete 2 Change

Casualty Last Name First Name Ml D.O.B. Age

1

r Time of

Injury

1 1 1 Home Address

" ' - ' I. 1 ,

Telephone

GA

GB

GC

GD

GE

GF

1 Male

2 Female

1 Fire Casualty 2 D Action Casualty 3D EMS Casualty rr

1 D Injury 2 Death

AFFILIATION

1 n Fire Service 2D Other Emergency Personnel 3 n Civilian Familiarity With Structure Location at Ignition Condition Before Injury

Condition Preventing Escape Activity at Time of Injury Cause of Injury

Nature of Injury Part of Body Injured Disposition

D See Remarl<s on Back CH See Additional Report

'casualty Number 1

1 1 1

1 Delete 2 D Change

GA

GB

GC

GD

GE

GF

Casualty Last Name First Name Ml D.O.B. TAge

1

1

f Time of

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1 '11 Home Address Telephone

SEX CASUALTY TYPE SEVERITY AFFILIATION lD Male lD Fire Casualty lD Injury lD Fire Service 2D Female 2D Action Casualty 2D Death 2D Other Emergency Personnel 3D EMS Casualty 3D Civilian

rFamiliarity With Structure

p L

rLocation at Ignition Condition Before Injury

Condition Preventing Escape ^Activity

, L at Time of Injury Cause of 1 njury

, L.

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1 CI See Remarks on Back CD See Additional Report

Casualty Number

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W Time of njury GA ,

GB

GC

GD

GE

GF

Casualty Last Name Age

Home Address Telephone

SEX

1 D Male

2 D Female

CASUALTY TYPE

1 D Fire Casualty 2D Action Casualty 3 EMS Casualty

SEVERITY

1 D Injury 2 Death

AFFILIATION

1 [~] Fire Service 2 Q Other Emergency Personnel SD Civilian Familiarity With Structure Location at Ignition Condition Before Injury

Condition Preventing Escape Activity at Time of Injury Cause of Injury

Nature of Injury Part of Body Injured Disposition

D See Remarks on Back D See Additional Report

Officer in Charge (Name, Position, Assignment) Date

Member Making Report (If Different From Above) Date

4

270
FIGURE 5

PERCENTAGE OF ALARMS REPORTED BY TIME OF DAY

0 His

TIME OF DAY

Source: Ohio, 1/1/76 - 12/31/76. Figure 5 is based on preliminary

data from a pilot test system and is presented for illustrative

purposes only; it should not be presumed to be accurate.

271
FIGURE 6

PERCENTAGE OF INCIDENTS BY DAY OF WEEK

J I I I I I SUN MON TIJES WED THUR FRI SAT

DAY OF WEEK

'

Source: Ohio, 1/1/76 - 12/31/76. Figure 6 is based on preliminary

data from a pilot test system and is presented for illustrative

purposes only; it should not be presumed to be accurate.

272
Table 1

Dollar Loss by Type of Structure

Type of Structure $ Loss, In 1000 's

Building with one use $ 114,913

Building with two or more uses 16,642

Open structure 386

Air-supported structure 26

Tent 8

Open & platform 21

Underground structure 2 Not a structure 96

Other structure 867

Source: Ohio, 1976. Table 1 is based on preliminary

data from a pilot test system and is presented for

illustrative purposes only; it should not be presumed

to be accurate.

273
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274
Table 3

Types of Construction

1. Fire resistive.

Includes BBC Types lA, IB; SBC Type 1;

UBC Type 1.

2. Heavy timber.

Includes BBC Type 3A; SBC Type III;

UBC Type III (HT)

.

3. Protected noncombustible or limited combustible.

Includes BBC Type 2A, 2B; SBC Type II, IV (1 hr.);

UBC Type II, IV (1 hr.).

4. Unprotected noncombustible or limited combustible

not qualifying for 3. Includes BBC Type 2C;

SBC Type IV; UBC Type IV (N)

.

5. Protected ordinary.

Includes BBC Type 3B; SBC Type V (1 hr.);

UBC Type III (1 hr.).

6. Unprotected ordinary.

Includes BBC Type 3C;

7. Protected wood frame.

Includes BBC Type 4A;

UBC Type V (1 hr.).

not qualifying for 5.

SBC Type V; UBC Type III (N)

.

SBC Type VI (1 hr.);

8. Unprotected wood frame, not qualifying for 7. Includes BBC Type 4B; SBC Type VI; UBC Type V (N)

.

9. Type of construction not classified above.

0. Type of construction undetermined or not reported.

Source: NFPA 901, 1976.

275
Table 4

Number of Residential Fires and Associated Dollar

Losses by Construction Type

Cons true tion No. of Residential Dollar Loss

iype Fires m 1 nousanus

r ire resistive QRn yo\J z9 , 7R9 / oz Heavy t imber Protected non- combustible J J J. Unprotected non~ combustible 329 955

Protected

ordinary 2,676 8,348

Unprotected

ordinary 2,019 8,566

Protected wood

frame 3,477 12,202

Unprotected

wood frame 5,844 20,638

Source: Ohio, 1/1/76 - 12/31/76. Table 4 is based on preliminary

data from a pilot test system and is presented for illustrative

purposes only; it should not be presumed to be accurate.

Table 5

Method of Construction

1. Site built structure.

2. Factory built, site assembled.

3. Factory built modular.

4. Factory built mobile.

9. Method of construction not classified above.

0. Method of construction undetermined or not reported.

Source: NFPA 901, 1976.

276
Table 6

Number of Residential Fires and Associated Dollar

Losses by Method of Construction

Method of No. of Dollar Loss

Construction Fires in Thousands

Site built

structure 15,452 55,215

Factory built,

site assembled 220 498

Factory built

modular 77 490

Factory built

mobile 601 4,097

Source: Ohio, 1/1/76- 12/31/76. Table 6 is based on preliminary data from a pilot test system and is presented

for illustrative purposes only; it should not be presumed

to be accurate.

Table 7

Form of Heat Ignition

1. Heat from Fuel-Fired, Fuel-Powered Object.

2. Heat from Electrical Equipment Arcing, Overloaded.

3. Heat from Smoking Material.

4. Heat from Open Flame, Spark.

5. Heat from Hot Object.

6. Heat from Explosive, Fireworks.

7. Heat from Natural Source.

8. Heat Spreading from Another Hostile Fire (Exposure).

9. Other Form of Heat of Ignition.

Source: NFPA 901, 1976.

277
Table 8

Type of Material First Ignited

1. Gas.

2. Flammable, Combustible Liquid.

3. Volatile Solid, Chemical.

4. Plastic

5. Natural Product.

6. Wood, Paper.

7. Fabric, Textile, Fur.

8. Material Compounded with Oil.

9. Other Type of Material Ignited.

Source: NFPA 901, 1976.

Table 9

Form of Material First Ignited

1. Structural Component, Finish.

2. Furniture.

3. Soft Goods, Wearing Apparel.

4. Adornment, Recreational Material.

5. Supplies, Stock.

6. Power Transfer Equipment, Fuel.

7. General Form.

8. Special Form.

9. Other Form of Material.

Source: NFPA 901, 1976.

278
Table 10

Ignition Factor

1. Incendiary.

2. Suspicious.

3. Misuse of Heat of Ignition.

4. Misuse of Material Ignited.

5. Mechanical Failure, Malfunction.

6. Design, Construction, Installation Deficiency.

7. Operational Deficiency.

8. Natural Condition.

9. Other Ignition Factor.

Source: NFPA 901, 1976.

Table 11

Deaths and Injuries by Ignition Factor

Ignition Factor No. of Deaths No. of Injuries

Incendiary 9 297

Suspicious 8 307

Misuse of heat of ignition 58 796

Misuse of material ignited 17 514

Mechanical failure 35 720

Deficient design 5 180

Operational deficiency 51 409

Natural condition 3 54

Other 4 15

Source: Ohio 1/1/76 - 12/31/76. Table 11 is based on preliminary

data from a pilot test system and is presented for illustrative

purposes only; it should not be presumed to be accurate.

279
Table 12

Extent of Flame Damage

1. Confined to the object of origin.

2. Confined to part of room or area of origin.

3. Confined to room of origin.

A. Confined to the fire-rated compartment of origin.

5. Confined to floor of origin.

6. Confined to structure of origin.

7. Extended beyond structure of origin.

8. Not a structure fire.

0. Extent of Flame Damage undetermined or not reported.

Source: NFPA 901, 1976.

Table 13

Detector Performance

1. Detector (s) in the room or space of fire origin,

and they operated.

2. Detector (s) not in the room or space of fire origin,

and they operated.

3. Detector (s) in the room or space of fire origin, and

they did not operate.

4. Detector (s) not in the room or space of fire origin,

and they did not operate.

5. Detector(s) in the room or space of fire origin, but

fire too small to require them to operate.

8. No detectors present.

9. Performance of Fire Detection Equipment not classified

above.

0. Performance of Fire Detection Equipment undetermined

or not reported.

Source: NFPA 901, 1976.

280
Table 14

Effectiveness of Automatic Sprinklers

Property Type A. With Sprinklers Operating

Average Damage Per Fire

B. Without Sprinklers

Average Damage per Fire

Residential JOJ J , / JO

rUDXlC ASSeiIlDJ.y o , yjo 7,0

Cjuuca Lion 1 U

Institutions 209 2,824

CDuOlco, * /^T" A O (iWXlXCcS f ^ T a C Q 7

Basic Industry 3,767 10,739

Manufacturing 8,994 22,559

Storage:

Residential Garage

Other storage

0

13,006

1,620

17,088

Total Structures

Source: Ohio, 1/1/76 - 12131/16.

Reported fire incidents shown here do not include all fires attended by fire

departments; estimated completeness is roughly 50%. Fires in which sprinklers were present but failed or for which information was not available are not

included. 1,083 structure fires falling in the category "Other Property

Type" have not been included because there were only two fires reported in

which sprinklers were operating. Table 14 is based on preliminary data from

a pilot test system and is presented for illustrative purposes only; it

should not be presumed to be accurate.

281
Table 15

Reported Fire Lossed for Major Occupancy Types —

California (CIFIRS 1975), Ohio (NFIRS 1976) Combined

Property Type Number of Fires Dollar Loss in Thousands

Residential, (Including

mobile homes) 63,555 155,609

Non-Residential structure 29,275 150,884

Mobile Property 43,037 24,732

Outside Property

(Rubbish, wildlands,

etc.) 148,112 22,183

TOTAL 283,979 353,408

Reported fire incidents shown here include only fires reported to the

states. Estimated completeness is on the order of 90% for California

and 50% for Ohio. Table 15 includes data from a pilot test system and

is presented for illustrative purposes only; it should not be presumed

to be accurate.

282

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283

PROPOSED DRAFT FOR NOISE CONTROL ABATEMENT

FOR THE CITY OF NEW ORLEANS

by

C. Curtis Mann, P.E.

Chief Mechanical Inspector

Department of Safety and Permits

City of New Orleans

New Orleans, Louisiana

The everyday sounds of simply existing can be very deceptive to

us as individuals. Music, for example, is soothing and refreshing to some persons while to others, the same music may be distracting and

unpleasant. The rock-and-roll that brings pleasure to one individual

might be found distasteful by another individual. We, as individuals

"on the street" do not think of noise unless it becomes irritating to us or "gets on our nerves." It has been said that sound is not a "noise" unless it annoys.

This paper is a search into some of the large cities' approaches

to their noise problems, with an added proposal to this same noise

problem for the City of New Orleans. Many controls are being

generated, developed and perfected, and as a result, future

generations should have a quieter environment in which to live and

work. Much is yet to be accomplished, however, and efforts toward

this goal should not be lessened or allowed to become diminished.

Key Words: Awakening to problems; deceptive sounds; establish legal

limits; tolerance level differences.

285
INTRODUCTION

To most people "noise" can be simply stated as unwanted sounds.

This is partially true because there are sounds that add to the

quality of the environment, just as there are those that do not. If

the sounds have an annoying result, it will always be defined as noise, and is generally considered as noise pollution.

The Federal Government, through OSHA, has implemented many

regulations regarding noise abatement and sound oriented safety. This

is fine if it can be implemented; however, in many of the instances

these regulations only confuse and frequently infuriate the regulated

parties. And, as is with most regulations, if they are not written

clearly and enforced properly, the parties will not take measures to

quiet their equipment nor will the users attempt to protect their

health from these hazards -- whether it is sight, breathing or hearing

Even though the Federal Government has maintained a sort of

"hands off" policy where the municipalities are concerned, their

knowledge and assistance has been of much value in helping those

localities and states to "get on their feet" and started in the right

direction.

In preparing regulations one caution should be considered,

though, in the form of possible regulatory overkill. This occurs if

everyone tries to get on to the dying object "noise" and wants to

regulate it to death. This occurs as a problem in all areas if the

regulations and controls are made without a complete understanding of

their implications. This can be seen happening with some areas of air

pollution, such as the control devices on automobiles and the energy

crunch, i.e.: Congress is taking a second look at the stringency of

the requirements again, and they, along with many constituents, are now saying that they would, in essence, "put up with" an increase in

the air pollutants, if they could trade off with an increase in the

gas mileage that amount that the emission control devices eliminated,

or if an increase could result in the country's self-sufficiency with

fuels

The regulatory overkill or excessive control can also occur if a State or municipality enacts such controls that are unfeasible and

impossible to live with. Many communities are hesitant to adopt or modify their noise laws because of these regulatory experiences.

Likewise, any ordinance adoption should be in scale with the needs of

that locality.

The State of Illinois has what is considered one of the most

comprehensive noise laws, and it applies to both the incorporated and

unincorporated areas. However, its complete compliance is almost

impossible without considerable instrumentation, expertise and a sizeable capital outlay.

There effectively can be no one ordinance that will fit all

communities. A California city repealed its quantitative ordinance

286
because it was of a too technical nature, and there was a lack of

necessary professional personnel for its enforcement. It is possible,

however, to utilize model noise ordinance guidelines and receive

provided assistance in helping to tailor a program to fit the local

conditions within the governing objective.

At this point it is necessary to emphasize that any ordinance

derived will have to concern what is "called" environmental noise or community noise. This is also referred to as non-occupational noise,

and includes zoning, curfews, traffic, nuisances, etc.

COMMUNITY NOISE

During the construction of any object, whether it is a bridge,

building, highway, monument or whatever, there will always be

associated noise, classed as the construction noise. Many spectators

will view the noise of constructing these objects, if he has access during construction, as simply the noise of necessity of progress.

This is acceptable, because he has the capability of leaving this area

for a quieter location, if desired, especially if the noise annoys

him. But what of the individuals that are confronted with noisy

conditions that he can neither move away from nor control? This type

of noise, expressed as "community noise" or non-occupational noise,

has to have some method of control or at least abatement. An in-part answer to this problem, the 1972 Noise Control Act passed by Congress,

required that the Administrator of the Environmental Protection Agency

(EPA) develop and publish a criteria with respect to noise. Document

550/9-73-002 was established for that purpose to reflect honest

appraisals of available knowledge relating to the health and welfare

effects of the noise pollution. The effect that noise have on people

will vary. Degraded hearing can occur and be attributed to the lack

of individual protection and exposure excesses that they subject or allow themselves to be subjected to, even in non-employment

conditions. There is a great area of response where hearing is

concerned. The human ear can discern withp^t pain, sounds ranging

from a threshold of detection to sounds 10 times as intense. This

is in contrast with the human eye, which responds to light from

detection threshold to an intensity of 105 times greater. A decibel

(dBA) is the measurement scale for the sound strength or pressure.

This decibel measurement is logarithmetic , and the units increase with

the amplitude of the levels that are measured. As an example; from a threshold of 0, to 60dBA for normal speech, to 170dBA for a turbo-jet

engine with afterburner.

One problem exists, human ears do not rate the pressure of noise

to judge loudness. The noise rating of loudness is complex because

the hearing is frequency (cycles per second) sensitive. The unit

Hertz, Hz, is the standard designation for frequency, and sounds with

frequencies in the 5,000-10,000 Hz range are the easiest to hear.

Frequency selectivity of the human ear can be shown by three

single frequency sounds of 50, 500, and 5,000 Hz. When the strength

of all three is adjusted until equally loud, the 50 Hz sound would be

287
19dBA stronger than the 5,000 Hz sound and 8dBA stronger than the 500

Hz sound.

Loudness can also be measured by filtering the microphone signal,

to reduce the strength of the low frequency signals, and to give more weight to the frequencies in the 5,000-10,000 Hz range, (frequencies

to which the ear is most sensitive). This is done with a standardized

"A" filter network that makes adjustments throughout the frequency

range that provides a decibel rating with a correction approximating

the sensitivity of the ears. This measurement is referred to as A-scale or dBA level.

The A-scale is widely used throughout the world and is the

adopted scale prescribing noise limits under the Walsh-Healey Act.

These limits are on the industrial environment and are for individual

protection. Every worker or citizen in a noisy environment should be aware of them. The exposure time limits decrease as the dBA levels

increase; such as exposure to 90dBA should be for no longer than 8

hours to no more than 15 minutes for sound levels of 115dBA or more. Exceeding the time limits at the dBA level could result in hearing

damage of the individual.

The A-scale is intended to match the response of the ear to low

intensity sound. There are some sound meters equipped with a "B" and

"C" scale and on later meters a "D" scale (proposed) will be

introduced. The "B" scale is intended to match the response of the ear

to sounds of moderate intensity, the "C" scale will then match the

responses of high intensity. The proposed "D" scale will primarily be

used to monitor jet aircraft noise.

SOUND INTENSITY

Sound may be stated in terras of three (3) variables; 1) Amplitude

(loudness), 2) Frequency (pitch), and 3) Duration (time). The sound

intensity is the average rate of the sound energy transmitter through

a unit area. These values, when reflected to "community reaction,"

will show that up to AOdBA no noticeable complaint action takes place

and 50dB-60dBA occasional complaints, to threats above 80dBA. The

full picture would not be realized, because additional data of

frequency and exposure time would have to be available before any

authoritative body could take corrective action against any violating

party. This still doesn't keep it from being a noise nuisance to the

complaining party.

Regarding intensity and human response, we should remember that

the ear is responsive to painful sound of a value much greater than

the least audible sound. This extremely wide variation in values is

what creates measurement and computation problems pertaining to noise,

and is why the level concept is desired. As an example, the sound

pressure levels are not directly additive to each other: i.e., a source producing an 80dBA sound, when added to another source producing 80dBA at the same distance, results in only a 3dBA increase,

and not doubling to l60dBA as might be expected.

288
Noise Types Affecting the Public Health

For proper evaluation of the effect of noise, one has to define

the types according to EPA criteria. The definition has to be fairly

explicit since a complex sound usually involves a mixture of sounds.

These sounds would vary in intensity, frequency, and pattern.

Different types would be "ongoing" and "impulse." Some examples of

ongoing noise are a waterfall, electrical substation, manufacturing

processes, traffic, engine areas, etc. The impulse noise is an acoustical event, such as a gunshot, lasting less than 500

milliseconds, and has a magnitude of at least 40dBA during that time.

Municipality Noise Ordinances .

Historically the regulatory control of noise has existed

throughout most of western civilization development. It has been

reported that the Romans even invoked restrictions on chariot use. Then, later, medieval towns adopted ordinances regulating both

stationary and mobile sources of noise. Ironwheeled carts could not

operate freely on paved streets and nighttime restrictions were imposed on noise related commercial and industrial activities,

including the town blacksmith.

The earliest noise regulations within the United States date back

to 1850; however, it was not until early 1900 that national concern began to develop. Even by 1930 there were less than 20 American

cities with laws regulating noise, and those were narrowly defined and

non-quantitative in nature.

The provisions of a New York Commission report, written in 1930,

included muffler requirements for motor vehicles and other internal

combustion engines; restricted building development in residential

areas between 5:00 p.m. and 8:00 a.m.; prohibited use of horns and

whistles; regulated peddlers, hawkers and venders, and prohibited

excessive noise from mechanical or electrical sound making or reproducing equipment.

Memphis, Tennessee, "proclaimed" the quietest city in America,

adopted several of these provisions in their 1938 municipal noise or- dinance regulating vehicles. Although it did not specify permissible

sound levels in decibels, their nuisance type or non-quantitative or- dinance became one of the most successful, due to an active

enforcement program.

In 1955, Chicago adopted a most influential zoning ordinance,

restricting noise related land use activity. This regulation

contained quantitative noise emissions expressed in decibels for

various octave bands. It represented a new approach to zoning which

placed restrictions not on the type of industry, but rather on its

performance in terms of noise emission. For the first time industry

was being regulated according to specific acoustical criteria, rather

than by a more vague nuisance provision.

289
Constitutionally, the power has been upheld to regulate noise for

the health, safety and welfare of the public. The municipalities can regulate nuisances through use of police power. A nuisance refers to

everything that endangers life or health, offends the senses, violates

decency or obstructs reasonable and comfortable use of one's property.

It is not at all surprising, then, that the majority of any municipal

noise ordinance within the United States is based on nuisances. It

also should be noted that even though most regulation exists for

nuisance, other noise types exist, such as Zoning, Vehicle, Building

and Aircraft.

Statistically the enforcement of nuisance ordinances containing

provisions of the non-quantitative type have been ineffective.

However, in spite of the vagueness, the Courts have ruled that

nuisance type ordinances, or noise ordinances containing nuisance

provisions, are constitutional.

ZONING

Zoning noise ordinances are the quantitative or performance type.

In contrast, these type ordinances are based on acoustical criteria,

and, therefore, they are more objective in nature. The acoustical

criteria generally includes both the overall sound level measurements

and/or frequency (Hz) requirements. This type of ordinance is in use where zoning is the predominately affected area, and should not be

construed to exclude vehicles, buildings or aircraft, because they

also play a major role in regulatory criteria.

The current Zoning Ordinance for the City of New Orleans is a quantitative type; however, there is no current way to measure the

provisions and values that are given.

Any agency that is designated for the enforcement of the

quantitative type of ordinance has an advantage over a nuisance

ordinance due to the definition of the dBA level, but would have to

have the necessary equipment that is required to perform the sound

measurements that require enforcing. This type of equipment is

expensive to purchase and requires some training to operate and

understand. For this reason, any ordinance, of necessity, would have

to completely encompass rigidity and simplicity. It would have to be

comprehensive and complete, and yet simple enough to enforce so as not

to require too much, if any, specialization for its implementation.

NOISE CONTROL

A major item in an effective noise control program is sufficient

budget to support the necessary personnel and equipment. Despite the

fact that there are nearly 300 ordinances regulating city noise, an EPA conducted survey indicated that less than 20 cities have adopted

budgets to operate noise control programs.

290
In terms of manpower, New York ranks largest with a full staff,

with approximately one-half directly assigned to their Noise Abatement

Bureau. Chicago has full-time staff members in engineering and en- forcement. Professional staffers, however, are very difficult to

acquire, and the current demand for qualified professionals far

exceeds the existing supply. As such, some cities have either delayed

or abandoned their programs due in part to the unavailability of

technically qualified personnel.

One precaution in preparation of the control program should be to

make it as comprehensive as possible, for the technically affected

people (architects, engineers), and still have it simple and precise

enough for enforcement by non-technical personnel (police,

inspectors). The requirement of these two functions has to be an overlapping and not simply an adjoining function.

An additional precaution will have to be understanding of the

tolerance limits reflected in complaining individuals; i.e., the

simple honking of a horn on an automobile, ringing of a bell, blowing

of a whistle, etc., will not, by itself, singularly constitute a valid

complaint claim, or, at least a claim that any authority should follow

up on without a duration time limit specified.

A very high priority report to the Mayor of New York, with its

recommendations and comments, was very much responsible in helping to

steer New York officials toward controlling and abating the noise

problem that it faced. The Legal Subcommittee of the report

commission quoted, in a supplemental memo, some of the earlier New

York cases and how they related to smells, indicating that abating

smells was no different from that of abating noise -- giving the

following quotations as revelant:

"To constitute a nuisance it is not necessary that smell should

be unwholesome, but sufficient if it renders enjoyment of life

and property uncomfortable - it is sufficient if it produces that

which is offensive to the senses and impairs enjoyment of life

and property."

"It is not sufficient that it is merely disagreeable, it must be

an annoyance calculated to interrupt the reasonable enjoyment of

life and property."

Professor W. H. Lloyd, University of Pennsylvania wrote in the

Law Review:

"Nuisance means literally 'annoyance' - the fact that an occupation was commendable in itself and carried on in a proper

manner did not alone justify substantial injury to property or

the infliction of material discomfort upon the residents of a neighborhood .

"Indeed, air and sound conditioned houses may be the next luxury

when luxury is resumed, to the profit of our inventors and

engineers, who, having devoted one century to creating

pandemonium, may spend the next century abating it."

He wrote this in 1934.

291
COMPARISONS, COMMENTS, AND CONCLUSIONS

There is a similarity in the noise control laws and regulations

that are enacted by the various cities and states. For instance, the

State of New York prepared regulations and enacted them to apply where

there were no laws or ordinances of local government. If there were

local laws or ordinances, they had to comply or compare with at least

the minimujn regulation for the state. This would not preempt any

local government from enacting noise ordinances and could possibly

provide those governments with the opportunity to develop their own noise control programs tailored to their own local conditions. All of

the states primarily follow this type format, of giving the local

governments their option.

The Federal Noise Control Act of 1972 states that the

"....primary responsibility for the control of noise rests with State

and local governments...." The Federal Act, administered by the

Environmental Protection Agency, is designed to control the major

noise sources in commerce which require national uniformity of

treatment. With the exception of interstate railroad and motor

carrier standards, the act states that "...nothing precludes or denies

the right of any state or political subdivision thereof to establish

and enforce controls on environmental noise through the licensing,

regulation, or restriction of the use, operation or movement of any

product or combination of products."

One problem exists, however, because most of the cities treated

noise problems as a minor pollutant, with Air Pollution having and

being under the greatest control and covering the greatest amount of

defined limits. This would probably be because of the apparent

innocuousness and thinking that the offended person could move away

from the sound. The consensus of opinion of most of the legislators,

complainers, individuals, etc., usually is that air pollution can be seen whereas noise pollution of any type cannot, so, maybe "out of

sight, out of mind." But, as has been mentioned also, this is

probably due to the ease and simplicity with which noise erodes the senses of the ear. The damage is so gradual that it will almost go

unnoticed until a hearing problem actually exists and the damage is

irreparable. But then it is almost too late because hearing cannot be

corrected, as with the eyeglasses for eyes - it has to be supplemented

with a hearing aid.

Also, unlike air pollution control, noise pollution control

currently has no requirement for permit issuance to the various

locations for thier equipment usage. This is similar in most cities,

excepting that New York requires a permit to tunnel under the city and

requires a means for the prevention of unnecessary noise during the

tunneling process.

Agency permits for creating a noise disturbance in any city

should not be allowed, primarily due to the fact that abatement or control is the reason for the agency's existence. Noise permits

should be allowed only as means necessary to a particular end item,

function or project. When that end item, function or project was

292
finalized, the noise, allowed by permit, would also have to be

finalized, and any noise would then be restrictive per a nuisance or zoning limited decibel standard or requirement.

New York City has an extremely comprehensive and inclusive

ordinance. The desirous effect of control is easier to obtain if

there is no doubt as to the ordinance or regulation values or coverage. If the coverage is too sketchy or incomplete, the results

are left too much to interpretation; then, any decisions would

possibly result from favoritism or even unfavoritism. Therefore, to remove any of the doubts, the requirements and values with the

penalties should be included in order to be of value to the community

that it regulates. The enforcement then can be concise, and its

effectiveness can be a direct result of the enforcing agency. No

regulatory agency wants to have to interpret the regulations that are within its responsibility. If interpretation is unavoidable, then the

ordinance, being comprehensive for regulation, should also be simple

for this interpretation. And, if generally this interpretation is not

acceptable, then referral should be made to a Board of Appeals, but

only as a safeguard, since that would preclude the regulatory overkill

that was discussed earlier.

It is discouraging that most municipalities will not enact any

form of measurement or abatement until it is "forced" on them or it is

too late. Sometimes, cities will enact regulations strictly as a result of a court case in which the city or its citizens have been

involved; or enactment would result due to some type of discrepancy,

but the city would never enact on its own in order to provide good

governing regulations. Then the tendency is always to overreact to

the requirement with an unrealistic result. However, if much

forethought and planning is involved, a good ordinance for all of the

citizenry of the area or city can result.

PROPOSED NOISE CODE DRAFT INCLUSION

The most logical part of the New Orleans Building Code that

should be utilized for noise control and abatement is the chapter

pertaining to smoke control. Inclusion in this chapter, rather than

choosing a new or different chapter, is primarily because the

regulating has previously been provided, for Chapter #51, by the

Safety and Permits Department. In addition to this inclusion, it will

be easier to add additional articles to the existing chapter than to

add another chapter.

References to airport noise will not be included because it is

generally provided in the noise control documents as a separate

entity. Any attempts to make a proposed draft include airport noise,

still be comprehensive and possess simplicity for enforcement, would

most assuredly be so clouded that approval by any Board would be very

unlikely.

Traffic allowable noises are include primarily because the

Federal requirements have been stipulated long enough that any action

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on the part of a city, New Orleans, will attest to its attempts to

become responsive to the noise control area.

Enforcement, as proposed, will be one difficult part of the

ordinance because of manpower. One likely requirement could be to

utilize a commissioned force of inspectors similar to those provided

for in Article 215 of the Building Code for inspection of mechanical

equipment. In this article the Safety and Permits Department,

Mechanical Inspection Section, commissions qualified personnel of the

insurance companies within the city to inspect the applicable

mechanical equipment that their companies insure. The completeness of

the code of the City of New York is used as setting an example for

this proposal to follow. Similarities in other utilized noise codes

are interpreted as the excepted norm in cases where other alternate

values could not be found from the guidelines that the Federal

requirements have stated. This would, at least, allow the ordinance

the flexibility necessary and desired that would be common for any

municipality for which it is drafted. There would be many items that

the other larger cities would have in common that would not affect or concern New Orleans and vice versa. The proposal, therefore, reflects

this general thinking.

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BIBLIOGRAPHY

1. U. S. Environmental Protection Agency, "Public Health and Welfare

Criteria for Noise," Document 550/9-73-002, July 27, 1973.

2. New York State Department of Environmental Conservation,

"Proposed Regulations for the Prevention and Control of

Environmental Noise Pollution," August, 1973.

3. New York State Department of Environmental Conservation,

"Prevention and Control of Environmental Noise Pollution,"

August, 1973.

4. "Toward a Quieter City," report of the Mayor's Task Force on

Noise, City of New York, January, 1970.

5. Illinois Environmental Protection Agency, "Noise Pollution

Regulations," August, 1973.

6. Clifford R. Braddon, Municipal Noise Ordinances - A Status

Report, p. 42 & 45, Sound and Vibration , Vol. 7, May, 1973.

7. Charles S. Straub, "Hearing Loss and Accidents," p. 22,

Sound and Vibration , Vol. 8, January, 1974.

8. Public Act No. 133, Rules and Regulations of Commissioner of

Motor Vehicles, "Maximum Permissible Noise Levels," April, 1972.

9. City of Chicago, "Noise Pollution Ordinance," Chapter 17,

Department of Environmental Control, December 16, 1969.

10. City of New York, "Noise Control Code", Int. No. 661-A, Council

of City of New York, amended June 28, 1972.

11. City of Boston Air Pollution Control Commission, "Regulations for

the Control of Noise in the City of Boston."

12. "Baltimore Plans Highways for Minimum City Noise," Grant S. Anderson, F. Gottemoeller , D. G. Page, p. 74,

Civil Engineering - ASCE , September, 1972.

13. Frank L. Cross, Jr., "Assessing Noise Impact on the Environment,"

p. 51, Pollution Engineering , November, 1973.

14. Jerry Donavan & Tom Ketcham, "Transportation Noise - Measurement

and Evaluation," reprint from Sound and Vibration , October, 1973.

15. Public Law 92-574, "Noise Control Act," October 27, 1972.

16. T. Shultz and N. M. McMahon, "Noise Assessment Guideline," U. S. Department of Housing and Urban Development, August, 1971.

17. Brochures and Pamphlets: B & K Instruments, Inc.; Columbia

Research Laboratories, Inc.; Mine Safety Appliances; General

Radio

.

295

RESIDENTIAL ENERGY CONSERVATION BUILDING REGULATIONS AND

THEIR IMPACT ON THE BUILDING PROCESS

by

Melvyn Green, Principal

Melvyn Green and Associates, Inc.

El Segundo, California

In early 1977, a study was conducted under contract to the State

of California. This work was a portion of a larger contract from ERDA

to document the history problems and success of the California

residential energy regulations adopted in February 1974. The

resulting report, based on personal interviews with code enforcement

officials, architects, developers, contractors, material suppliers and

manufacturers, and homeowners, describes the impact and changes caused

by these regulations on segments of the building industry. This paper

will briefly discuss these impacts within the context of statewide

energy conservation building regulations.

In addition, the paper will summarize the procedures of the State

to develop and implement residential energy regulations. The paper

concludes with procedural recommendations for Federal, State, and

local government.

Key Words: Building regulations; enforcement; energy conservation;

legislation; standards development; survey findings;

training.

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I . INTRODUCTION

This paper discusses the impact on various sectors of the

building process by the adoption of residential energy conservation

regulations by the State of California. We will discuss the response

to these statewide regulations by local building enforcement agencies,

architects and engineers, builders and developers, material

manufacturers and suppliers, and the consumer (homeowner). Also the

administrative efforts by the State to develop, adopt, and implement

regulations will be discussed. The report identifies field experience

after two years of enforcement. This study was performed under

contract with the State of California Department of Housing and

Community Development (HCD) . The project was funded by the U.S.

Energy Research and Development Administration (ERDA) . This paper

will summarize both the States' report and our report. Our work

involved the actual field survey which included approximately 100

personal interviews; analysis of the data collection and

recommendations for various levels of government to ease the

implementation of energy conservation regulations.

II . BACKGROUND

Legislation

Legislation was passed in 1972 mandating the Commission of

Housing and Community Development, by January 1, 1974, to adopt rules

and regulations establishing minimum standards of energy insulation

for all new residential buildings. Funding for the development and

implementation of these was $35,000.

These rules and regulations were required to meet or exceed the

current FHA "Minimum Property Standards for One and Two Living Units."

Further rules and regulations independent of such standards were developed for hotels, motels, and apartment houses more than three

stories in height. The enforcing agency is the local building

department. Conditions for local adoption of more restrictive

regulations were established. Regulations are not retroactive.

Advisory Committee

An advisory committee representing necessary areas of expertise

was appointed to assist the Commission in the establishment of energy

insulation regulations. Separate legislation requiring the adoption

of minimum noise insulation standards for residential buildings also

required that an advisory committee be appointed. The makeup

specified for this committee was very similar to that required of the

advisory committee for the energy insulation standards. It appeared,

at the time, that it would be beneficial to form a combined advisory

committee. This proved to be less feasible than had been thought

since goals were different.

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Regulation-Adoption Process : The development and adoption of

energy insulation standards for the State of California involved the

following:

Public advisory committee meetings.

Public fact-finding seminars.

Public hearings which were also meetings of the Commission of

Housing and Community Development at which standards could be

adopted

.

Public meeting of the Building Standards Commission.

The advisory committee meetings were basically working committee

meetings which were held both prior to and after the fact-finding

seminars and public hearings.

Two informal fact-finding seminars were held to obtain additional

data and public input on the proposed standards, one in the northern

and one in the southern part of the State.

As required by the California Administrative Procedures Act, a public hearing was held in conjunction with a meeting of the

Commission at which the energy insulation standards were proposed for

adoption. However, due to public input, the Commission elected not to

adopt the energy insulation standards at the first meeting. This

required more advisory committee meetings and a fourth public hearing

held in conjunction with a Commission meeting. At this meeting, the

Commission did adopt the energy insulation standards.

Since the energy insulation standards contained building

standards, approval was required and obtained from the Building

Standards Commission to check for overlap and conflict with other

building standards contained in State regulations.

Advisory Committee Meetings : The advisory committee appointed to

assist in the development of energy insulation standards held their

first meeting May 30, 1973. Ensuing meetings showed that many members were unable to attend consistently. A point to consider when

utilizing an advisory committee is that some provision should be made

to replace such members.

Public notification of the advisory committee meetings to develop

energy insulation standards for residential buildings was accomplished

by advertising in a trade newspaper and by mailing to interested

parties. Attendance by the public at the committee meetings varied,

increasing as the time for adoption approached. Meetings were held at

various locations in order to provide wide opportunity for attendance.

State staff assistance to the advisory committee during

development of the energy insulation standards was substantial.

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In developing the standards, the advisory committee had, in

addition to the legislative requirements, the following objectives in

mind:

The standards should result in significant energy savings.

The standards should allow design flexibility.

The standards should be compatible with present California

Residential-construction techniques so as to minimize the impact

on the builder.

Eventually, four subcommittees were established to cover the

following topics:

Data needs.

Enforcement problems.

Energy insulation standards.

Energy design manual.

Since the standards were adopted in February 1974, several

changes were developed by the commission of Housing and Community

Development in response to better input data or design and enforcement

problems. Such changes included:

Subsection (c), related to alternate provisions, was changed to

permit overall building envelope heat loss calculations and to allow

credit for designs utilizing nondepleting energy systems.

Subsection (d)(2), which contains the definition for degree day, was revised to clarify that it is related to the annual heating load

and not just the winter season of the year. The degree standards

would be applicable to all new residential buildings and did not

address additions, alterations, or relocated buildings. It was determined that if the existing building was required to be

constructed in conformance with the standards, then it made sense that

an addition to that building be required to comply with the standards.

In California, there are over 500 city and county building

departments which enforce building regulations. Up to the time of the

enactment of the energy insulation standards, the regulations enforced

by building departments dealt with health and safety items only.

Enforcement questions for the insulation standards required special

consideration.

The main concerns of the enforcement subcommittee were:

That the standards would be implemented uniformly throughout the

State.

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That the cost of the enforcement of the standards would be

minimal to the consumer.

That the enforcement officials understand the terminology used in

the standards.

The enforcement subcommittee recommended that an energy design

manual be developed to assist in the implementation of the

standards

.

The second recommendation of the enforcement subcommittee was that the regulations require that a compliance certificate be provided

by the installer and the builder upon completion of the installation

of insulation.

The third recommendation of the enforcement subcommittee was to

have the standards become effective one year after the date of

adoption of the standards. This one-year period would provide

sufficient time for users to become familiar with the standards and to

allow for a smooth transition period for compliance with the

standards

.

ENERGY DESIGN MANUAL

The Energy Design Manual for Residential Buildings was developed

for the purpose of assisting in implementation of the energy

insulation standards.

The subcommittee members charged with providing input for the

development of the manual consisted of representatives of the building

industry, utility representatives, suppliers, insulation contractors,

enforcement officials, and designers.

The Manual contains administrative and technical information,

including definitions, examples of standard insulation and glazing

details, and climatological information. Also included are sections

covering energy fundamentals and design.

Even though this manual was only a guide, it soon became an indispensible tool in the implementation of the standards and remains

so today.

TRAINING AND PLAN CHECKING

As the development of the energy insulation standards progressed,

it became apparent that a training program would be necessary in order

to have orderly implementation of the standards. It was decided to

develop a training program using the Energy Design Manual as the main

training tool. The Department was left with the task of developing a statewide training program with a very limited budget.

301
Another problem was the timing of the training program. Work on

the Energy Design Manual did not begin until after the standards were

adopted. The Manual did not become available to the public until after

the standards became effective. This delay further complicated the

proposed training program.

With these obstacles of funding and timing, the Department

proceeded on the development of a statewide training program.

It was decided that the following criteria would be used in

setting up the training program:

The training sessions would begin no later than September, 1975.

The main emphasis of the training would be directed toward

building inspectors who enforce the standards. It was felt that

if the enforcement officials could develop a thorough

understanding of the standards, uniform implementation would be

obtained. In addition, these trained officials could provide

assistance to builders and consumers in their jurisdications

The instructors of these courses would consist of Department

staff and advisory committee members.

The Department would try to notify all groups and individuals who

would be affected by these standards.

The Department would make an effort to have a Department

representative familiar with the standards at any public meeting

concerning energy.

After the first few training sessions were held, it became

apparent that the following changes would be needed in the program:

The sessions would have to start with basic heat transfer theory

due to the general lack of familiarity with heat transfer

terminology.

The training sessions were too short (2 to 4 hours). It was evident that very little could be accomplished unless the

sessions were extended to a minimum of eight hours. Several

all-day sessions were incorporated into the training program

which eliminated some of the apparent problems; however, due to

the time available, a sufficient number of these sessions could

not be provided.

When the energy insulation standards became effective, certain

implementation problems still existed. The major problems were concerned with the following areas:

Unawareness of the standards by the general public, builders, and

designers

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Limitations of design flexibility due to the restrictions on glazing.

Increased costs due to the standards.

General reluctance on the part of the public to accept the need

for such standards.

Most of these areas which were problems at the time the standards

became effective have now been resolved.

III. SURVEY FINDINGS AND ANALYSIS

INTRODUCTION

Studies were conducted after the standards had been in effect for

approximately two years to determine the problems encountered in

implementation, enforcement, and design. Data was collected by

surveying enforcement officials, builders, and developers, architects

and engineers, manufacturers and suppliers, and consumers. Interviews were selected to provide a representative cross section, considering

the various sizes of city and county building departments, various

climatic conditions and geographic locations throughout the State.

The consulting firm of Melvyn Green and Associates, Inc., El

Segundo, California, was retained to assist in the collection of data

and the preparation of recommendations. Mr. Green's report, "The

California Residential Energy Regulations -- Their Impact on the

Building Process," discusses his survey methodology and findings and

presents recommendations based on the findings.

An independent survey was performed by the Department of Housing

and Community Development, at interview locations not covered by the

consultant. This provided a broader data base and the opportunity to

compare the findings of the two surveys.

The findings represent the opinions and experiences of the

individuals interviewed only and should not be construed to mean that

all others agree with these opinions. Summaries of groups surveyed

follow:

A. ENFORCEMENT AGENCIES

The energy insulation standards for new residential buildings in

California are enforced by local enforcement agencies, generally the

building department. The two principal functions of these agencies to assure compliance with the standards are plan review and field

inspections. As a result, it is the local enforcement agency which

has the daily contact with the builders and designers and is

confronted with the question and problem.

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Most of the questions regarding the standards are answered at the

building department level. The Energy Design Manual is used as a reference. Sometimes, other enforcement agencies such as counties are consulted, or questions are referred to the State.

Plan Review : Plans, and calculations when required, are checked

for compliance with the energy insulation standards. R values of

required insulation are required to be shown on the plans.

About 95 percent of the dwellings constructed meet the specific

or prescriptive requirements of the standards. The remaining 5 percent utilize the alternative of providing heat loss analysis

calculations to show the equivalency of the designed house. Some

rural areas report that the heat loss analyses submitted are poorly

performed and people qualified to do these calculations are hard to

find.

Inspection : Due to lack of time and manpower, many enforcement

agencies do not inspect the installation of insulating products.

These agencies accept the certificate of installation signed by the

builder and installation installer, with spot checks in some cases. The majority of the enforcement officials feel the certificate means

full compliance with the standards; however, no one certifies

compliance with the glazing and weatherstripping requirements

involved. One agency thought that building departments should only be

required to enforce items related to health and safety. Hostility

toward State mandated regulations was also mentioned. The remainder

of the enforcement agencies (approximately 60%) are inspecting the

installation of the insulating products. Frequently a copy of the

signed certificate of installation is required prior to the final

inspection. Some field reports note poor workmanship in the

installation of insulation and weatherstripping.

Some agencies were not aware of the requirements for

weatherstripping or labels on aluminum windows, and thus were not

inspecting for these items.

Administration : Fee increases to offset the increased plan check

and inspection tasks required varied widely. Frequently, the

enforcement agency relied on the increased valuation provided by the

insulation for additional income to cover the required services.

Other cities and counties increased their fees in varying ways.

Although extra time is required to enforce the standards, few

agencies reported hiring additional personnel. Local governing bodies

appear reluctant to allow the building department to hire extra

personnel because of new standards, even when income is adequate to

support the position. As a result, when work is added, priorities on what gets done change.

Adequacy of Standards : Enforcement agencies generally felt the

standards were adequate. Some thought they should also cover additions to existing buildings, HVAC systems, water heating, and other

energy consuming elements within the building.

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Some enforcement agencies by code amendment, required all

additions to be insulated even though the State standards do not

require it. Generally, the glazing area was not considered in these

cases

.

In some areas, the requirements for slab and underfloor

insulation were considered too restrictive because of the difficulty

of installation.

In areas where degree day zones adjoin, the significant change in

the requirements between zones is questioned. An example is along the

Eel River in Humbolt County. One side of the river is less than 4500

degree days, while the other is slightly over 4500 degree days. The

local enforcement agencies expressed the opinion that there is a significant increase in requirements; i.e., double glazing, in a short

distance and perhaps a more gradual scale would be appropriate.

Product Standards and Acceptance : Few enforcement agencies were

aware that insulation is labeled and tested under a voluntary standard

as compared to the independent laboratory testing and inspection

process for traditionally regulated building products. Consensus is

that a product certification and labeling program would be very

helpful for plan checking and inspection and also provide needed

consumer protection. There is also concern over conflicts between

fire safety and energy conservation regulations.

Educational : Virtually all local enforcement agencies

interviewed received some training relative to the regulations,

usually at a state-conducted seminar or a building official's meeting.

Information received at seminars or classes was used for training of

other personnel within the agency. Many who attended seminars stated

that the technical content of the class materials was not at the level

they would have preferred.

One-man enforcement agencies were frequently unable to attend any

class or seminar since they had no one to relieve them.

An area of significance is the manner in which the local agencies

implemented the standards. The building department seemed to be the

principal vehicle for educating the public about the regulations. The

initial six months of the program was the most difficult period for

implementation

.

Much of this related to the changing of the regulations occurring

during that period. Local enforcement agencies resent having to act

as front man for the State and felt the State should take

responsibility for the education of architects, designers, and

contractors. However, a frequent comment was that the energy

conservation standards were the easiest to implement of all recent

State mandated regulations since the contractors and homeowners could

see the return on their investment.

Nearly all the enforcement agencies were familiar with the Energy

Design Manual for residential buildings and found it to be useful. In

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a few cases, the manual is treated as the law instead of a guideline,

and if a material, method, or assembly is not contained in the manual,

it is not permitted. The only complaint relative to the manual was that it was not available soon enough.

Suggested changes to the manual were:

Provide a simplified version.

Provide more data on insulating materials.

Provide more examples for average construction.

Provide example calculations for log cabin type buildings.

Develop simple rules of thumb for tradeoffs.

Provide specific insulation installation details.

Provide construction details for open beam ceilings, underfloor

and slab insulation, and unvented roof panels.

B. BUILDERS AND DEVELOPERS

The builder is the individual in the design/construction process

who must ultimately execute the work required by the standards and

represented in the drawings and specifications. Builders must

understand both the requirements and the intent of the standards in

order to put them into effective practice. Builders often feel they

are not receiving enough assistance from the State. Many feel that

insufficient efforts are made to communicate with them.

Design : Builders reported that almost all houses comply with the

prescriptive design requirements. Where compliance problems arise,

the design is generally changed to meet the prescriptive requirements.

Builders of higher quality tracts and custom houses use alternative

heat loss calculations more frequently; especially in areas where the

view is a saleable commodity. A few use the alternative method for

all houses.

Design practice has been affected, and various minor problems and

complaints were voiced with respect to this. Some problem has been

encountered in satisfying the requirements where open beam ceilings

are used. Design problems are also occurring in areas of high

humidity; the specified details may result in significant moisture

problems. Builders are not typically installing smaller HVAC units, even though the buildings are better insulated.

Construction : Most builders had no trouble with implementation

of the regulations. Variation in enforcement and interpretations

among enforcement agencies sometimes made the job difficult.

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With respect to labor availability, there were no complaints

about insufficient numbers of subcontractors, although there was some grumbling about "sloppy work." Predictably, areas with a limited

construction season have more problems with delays and scheduling than

do those where construction is possible year-round.

Adequacy of Standards : The standards are generally felt to be

accepted, although typical complaint recur within environmental zones,

showing patterns which point to deficiencies in regional applicability

of the standards. Complaints occurred primarily in the severe-climate

zones; the general consensus in mountain areas is that insulation

requirements are adequate, and in desert areas, that the glazing and

orientation provisions do not really address the problem; and that the

insulation requirements are designed to save on heating energy rather

than air conditioning.

Product Standards : Builders generally consider the performance

of labeled products to be consistent with manufacturers claims. Some

variability in window quality was noted. Solar products have proved

to be so unreliable that most builders would not consider installing

solar energy devices until independent and reliable testing for such

products is initiated. Many builders would like to see independent

testing and certification of all energy conservation products.

C. ARCHITECTS AND ENGINEERS

Involvement of architects and engineers occurs primarily in the

design of multi-family dwellings. Most architects and engineers make

use of the alternative heat loss analysis. It was found consistently

that the reason for utilizing alternative design provisions was to

provide more glass area -- for view, feelings of openness, and natural

light.

The most frequent mentioned design problem imposed by the

standards involves the detailing of an open-beamed (vaulted,

cathedral) ceiling. Concrete block is rarely used now because of the

difficulty in achieving wall insulation requirements. In the mountain

areas, underfloor insulation posed significant problems due to

moisture accumulation; alternative design details were called for.

The architect of a high-rise hotel noted difficulty in developing a system to satisfy the roof insulation requirements.

Design problems and confusion were caused by changes made to the

standards in the early stages of implementation. Problems were also

created by nonuniform interpretation by enforcement agencies, probably

caused by inadequate training relative to the standards. It was suggested that the State publish interpretations to achieve more uniform enforcement.

Adequacy of Standards : Several who work frequently with heat

loss analyses feel a performance standard would be more desirable than

the prescriptive standards now in force. As now written, the

standards seem to have spawned such "no-think" solutions as using

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single pane up to the allotted twenty percent and double pane for the

glass areas exceeding the limit. On the other hand, the opinion was expressed that the standards are pretty good now, and should not be

made more complicated by adding life cycle cost analysis, etc.

Educational : Many architects learned about the energy insulation

standards when applying for a building permit; one architect was told

by his developer-client. As a result, many designs had to be

re-worked to adjust glass areas when the standards first went into

effect. Few architects had received any training directly related to

the standards.

D. MANUFACTURERS AND SUPPLIERS

The effects of the standards on the insulation and glazing

industries were very different. The window manufacturers said they

already had windows which met the performance criteria before the

effective date of standards. Problems arose with lower quality models,

which were dropped or redesigned. The insulation manufacturers and

subcontractors, on the other hand, were not required to change their

products -- they only had to certify that their products were capable

of certain levels of resistance and label them accordingly.

Insulation subcontractors liked the standards and were well

prepared for their implementation. Insulation industry associations

were a significant force in formulating the content and scope of the

standards and in their adoption. The industry as a whole has not

experienced any unusual shortages of materials, but increased demand

has caused an allocation system to be set up in order to distribute

the products statewide. Complaints seem to be centered around

competitor's products.

Window manufacturers were generally opposed to the standards and

any new restrictions. The loudest complaints were in the area of

equity of compliance; i.e., they were complying but their competition

was not. Inspection practices regarding windows and their labels and

the window manufacturers noted that "unequal inspection creates an unfair market".

A mechanical contractor and supplier reports that it is standard

practice to design the HVAC system for the most critical home in a tract. The home with the critical orientation and greatest heat loss

is used for sizing the equipment for all the homes in the tract. This means that most of the homes would have oversized equipment. Heating

equipment sizes usually cannot be reduced since the standard equipment

sizing is controlled by the air conditioner size. Therefore, the

heating system is generally oversized because of the air conditioning

unit

Adequacy of Standards : Window manufacturers consistently

regarded the glazing standards as too restrictive. They observed that

an air conditioned house with windows which eliminated heat gain to

reduce cooling loads, worked to the detriment of the heating system in

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the winter. One suggestion, to remedy this situation, also heard from

some builders, was to eliminate the original cooling restrictions,

leaving only heating requirements, and instead place a performance

specification on the cooling unit itself.

E . CONSUMERS

The California Residential Energy Insulation Standards were designed to reduce energy consumption in the heating and cooling of

residential buildings and to benefit, ultimately, the consumer as well as the State as a whole. Therefore, in this study, it was thought important to conduct several representative interviews with

occupants of residential buildings constructed after the effective

date of the standards, recognizing that the information thus gathered

might be limited by the average consumer's lack of technical

sophistication in the field of energy conservation as well as his

late entry into, and lack of control in the building process.

Exceptions to these patterns would most likely occur in cases of

custom-home building, where an early and often more active

collaboration exists between the builder and homeowner. A significant

number of homeowners interviewed complained of problems due to poor

installation practices.

All of the homeowners interviewed felt that the regulations could

be strengthened. Windows, doors, and weatherstripping -- the most

visible features of the insulating package -- were most often

mentioned as problem areas. The standards seem not to address the

special cooling need of homes in very hot summer areas. There appears

to be a consumer readiness for home energy conservation, but this is

tempered by the consumers lack of sophistication in energy

conservation matters.

IV. RECOMMENDATIONS

The following is a brief summary of recommendations resulting

from analysis of the data collected.

A. FEDERAL ROLE

The Federal Government should provide funds for the development

of educational material for all sectors of the building industry. The

goal would be to minimize resistance to the standards by those

affected and involved in the building process.

Funding for training and for demonstration projects should be

provided at the Federal level since energy conservation is a national

priority. Certain elements of energy conservation standards have a negative impact upon some industry groups; thus, there is little

incentive for the private sector to develop adequate training courses.

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B. STATE GOVERNMENT

Legislative : Legislation enabling the development of energy

conservation standards should stipulate that both prescriptive and

performance standards be developed.

Standards should not be limited to the envelope of the building,

but should include plumbing, electrical, and climate control systems

as well.

The legislation should fund continuing technical assistance to

local building departments which enforce the standards. This program

should include training in enforcement procedures, forms and

procedures for review of building plans and specifications,

development of an energy conservation manual, and adequate funding to

accomplish the program.

Development and Adoption of Standards : The utilization of a representative advisory committee, to assist in the development of

energy standards, provides an opportunity to obtain expertise and data on construction practices and the effects of such standards on housing. There should also be funding for consultants to the advisory

committee. Even if the advisory committee concept is not used, funds

for consultants should be provided.

The lack of public attendance at advisory committee meetings

points out the need for additional notification and dissemination of

information to obtain the interest of the public.

Administrative : Improve dissemination of standards and technical

aids to all sectors of the building industry.

Supporting Implementation Information : The State should study,

identify, and make available for the information and use by local

agencies, information relative to the following:

Cost impact of the standards -- how much will the additional

inspection and plan review cost the city.

Plan check and inspection aids for the several geographic regions

of the State to assist local agencies in implementation of the

standards

Communication Channels : Two-way communication between State and

local enforcement agencies should be established by a toll free phone

number, staffed by individuals competent to answer technical

questions

IMPLEMENTATION AND ENFORCEMENT

Public Awareness : An extensive effort must be made to make the

public aware of energy standards prior to their implementation.

310
Education and Training : A comprehensive educational and training

program is necessary for uniform implementation and enforcement of

energy standards.

Such a program must be made available to all affected by the

standards. This is especially needed by the officials who enforce the

standards and have the daily contract with those who must comply with

them. The training sessions should be confined to small geographic

areas to minimize travel.

A simplified handout should be developed, depicting conventional

construction and what is required for conformance with the

prescriptive requirements of the standards. There is also a need for

education related to good construction practices and details for the

insulation of open beam ceilings, floors, slabs, and unvented roof

panels. Industry research and development of new and better methods

are needed.

C. LOCAL GOVERNMENT

Staffing : Local government officials should understand the need

for energy conservation and that its effective implementation will

rely on adequate staffing of local building departments.

Communications : Local enforcement agencies should be encouraged

to develop better communication with contractors and designers to ease implementation of energy standards.

Relations with the State : Local enforcement agencies should be

encouraged to provide input to the State regarding standards,

implementation problems, and technical problems.

Equal Enforcement Needed : Local enforcement agencies should

uniformly enforce the standards.

TECHNICAL

Inspection Sequence : Local enforcement agencies should be

encouraged to require a minimum of one additional called inspection

after rough-in to inspect insulation. Additional called inspections

for floor and rigid roof insulation should be specified when

appropriate. Development of the enforcement sequence could be in

concert with local contractors.

Educational : Staff personnel at all levels should be encouraged

to take educational offerings relative to energy conservation. Local

officials should be encouraged to provide time off, tuition

reimbursement, etc., as required for personnel to attend such classes.

Product Approval and Standards : This aspect must be strengthened

to improve acceptance of energy conservation products. Testing,

certification, labeling, installation, and fire resistance of

insulating products should be considered in any standard developed.

311
The R value for various insulating materials is open to

self-certification by the manufacturer, or it is based on R values

listed in engineering handbooks. Similar products are advertised and

sold with a wide range of R values. Uniform test procedures and

certification methods need to be established.

Also, some products are not properly labeled, creating field

inspection problems. Labeling criteria need to be established.

Installation of insulating products is also important to the

effectiveness of products. Installation instruction should be

required

312
THE ENERGY CONSERVATION CODE:

IMPLEMENTATION IN NEW MEXICO

by

James 0. Dritt, Ph.D.

Senior Research Associate

New Mexico Energy Institute at

The University of New Mexico

Officials of the State of New Mexico agreed in September 1976 to

adopt the proposed Chapter 53 of the Uniform Building Code (UBC)

published by the International Conference of Building Officials (ICBO)

with scheduled implementation of July 1, 1977. This paper describes

the key elements of an implementation scheme through the utilization

of innovative research, development of code Applications Manual, and

the conduct of a formal statewide training program for all building

officials

.

Key Words: Building code; code officials; effective "U" values;

energy conservation; implementation; professional

competence; training programs,.

313
INTRODUCTION

Because of the prospect of dwindling energy supplies and

skyrocketing energy costs, energy conservation in buildings is a major

focal point of national policy and legislation as well as the subject

of wide interest to the man-on-the-street

The 1973 oil embargo, and the subsequent energy crisis, had the

positive effect of making us all aware of serious national energy

problems in terms of the enormous quantities of energy consumed and

the equally enormous amounts of energy waste.

In the haste to develop analytical tools to achieve energy

savings in buildings, a national consensus standard was assembled

which relied on off-the-shelf and widely accepted techniques centering

around established steady-state "U" values. The "U" value designates

the amount of heat (Btu's) that will pass through one square foot of

material in one hour when the temperature on one side is different

from the temperature on the other side. U values were used for many

years to help determine the size of heating and cooling equipment

required to condition the interior of a building for human comfort.

The assumption was made that a building in a given area of the country

would be subject to maximum and minimum temperatures during the

hottest and coldest days. Steady-state heat transfer calculations were then made for those extreme conditions -- how much heat would be

lost through the building components (roof/ceiling, walls, and floors)

made of materials which would give a particular U value. This method

established the maximum amounts of energy which could possibly be

required for comfort. The maximums would tell the heating, ventilating and air-conditioning engineer or contractor the size of

equipment needed to meet these extreme "peaks". Though it was inaccurate in some respects, the sizing procedure worked reasonably

well, because it was not important to be more precise when energy was cheap

The problem with the method of using steady-state, laboratory U

values in such an analysis, as in Project Conserve, is that it does

not consider or reflect diurnal temperature cycles, solar radiation, mass effect, thermal storage, re-radiation to the night-black sky, or wind conditions. As a result, it has become apparent that the

steady-state analysis of energy consumption is at best approximate; it

always results in the oversizing of heating and cooling equipment from

30% to 70%. This oversizing uses more energy than necessary, as well

as costing more for the oversized equipment.

In spite of these shortcomings — "peak" analysis rather than

accounting for effects of local climatic conditions — the building

codes proposed for adoption by various States throughout the nation

regulate the thermal performance of the building envelope based on the

steady-state analysis.

314
THE NEW MEXICO RESPONSE

The desire to save energy and natural resources is no less

intense in New Mexico than anywhere else in the nation -- even though

the State is a large energy producer and a relatively small energy

consumer.

Under the leadership of Governor Jerry Apodaca, State officials

agreed in September 1976 to adopt the proposed Chapter 53 of the

Uniform Building Code (UBC) published by the International Conference

of Building Officials (ICBO), Implementation was scheduled for July

1, 1977. It was recognized, however, that the strict interpretation

of the code would jeopardize certain traditional and innovative

construction techniques unique to New Mexico. Therefore, this action

was taken with the proviso that research would be undertaken to study

the code and devise methods for implementing the provisions of the

code specifically for New Mexico. Another stipulation was that a training program be developed and presented to building officials

throughout the state prior to the code implementation date.

Research and development projects funded by the New Mexico Energy

Resources Board were immediately initiated through the New Mexico

Energy Institute at The University of New Mexico. These projects were

to focus on innovative concepts which would specifically address the

shortcomings of the code and advance the technological state-of-theart

in heat transfer and energy conservation.

An analysis of the problems of implementing the energy

conservation code in New Mexico resulted in the conclusion that the

key problem was a failure to distinguish between the steady-state U

values of different materials and their dynamic performance.

Therefore, the main thrust of the research centered on New Mexico's

varying climatic regions (from low arid desert to high Canadian

alpine) characterized by large diurnal temperature differences and a very high incidence of solar radiation. It is well known that solar

gains are present in every building and may be used to effect a net

reduction in the total building energy requirements. Hence, the

research objective was to establish a quantitative basis for the

incorporation of the basic concepts of solar flux through windows and

onto walls into architectural design. The proposed strategy was to

replace steady-state U values, in the overall prescriptive analysis,

with effective U values which characterize the dynamic performance of

various wall types. In essence, the effective U value, which takes

into account solar input and time-dependent boundary conditions, is a measured average heat transfer or, more specifically, the ratio of the

average heat flux on the inside surface of the wall over an extended

period of time to the average temperature difference between inside

and outside over the same time interval.

The preliminavy results of the theovetioal analysis of effective

U values have been astounding; they have led to a better understanding

and documentation of the performance characteristics of building

components in the climatic regions of New Mexico. Most importantly , the

resea:rch has pointed the way toward implementing the prescriptive energy

conservation code through the utilization of performance-based criteria.

315
The unique aspect of these efforts in New Mexico is reflected by

the fact that the results of this innovative research are being

applied directly to implementation of the energy conservation code by

utilizing effective U values in determining code compliance.

Effective U values for 26 different wall types in 11 climatic regions

of New Mexico have been tabulated and disseminated throughout the

State. Thus, the potential for achieving energy savings in new

structures will be greatly enhanced while obtaining construction

savings at the same time.

While energy conservation codes specifically address new buildings, a great deal of insight on all existing buildings may be

obtained in relation to energy consumption data, energy audit

capability, and developing retrofit opportunities. Once the

performance of building components is thoroughly understood and

documented, a realistic cost/benefit life cycle analysis of retrofit

actions may be recommended. This potential makes technology transfer

to other states even more significant.

THE TRAINING PROGRAM

Recognizing the complex language of the energy conservation code

and the degree of sophistication required to understand it, the State,

through the Energy Resources Board, awarded contracts to the New

Mexico Energy Institute to 1) develop an "Applications Manual"

interpreting Chapter 53 specifically for New Mexico, and 2) develop

and conduct a training program for building officials based on the

manual. This work, to be completed by 30 June 1977, was undertaken

with the stipulation that it would be fully coordinated with the New

Mexico Construction Industries Commission as well as a review

committee consisting of representatives of various building industries

throughout the State.

As the agency legally responsible for the enforcement of building

codes adopted by the State, the Commission exercises administrative

control over all building officials, whether employed by individual

municipalities or by the State, and is the largest source of

information concerning them. This information and other technical

assistance provided by the Commission staff proved vital to the

development and implementation of the training program.

Further assistance was provided through participation with the

ERDA-sponsored program entitled "Energy Conservation Technology

Program for State and Local Building Officials" developed by NCSBCS, a consortium of building code organizations. Information acquired

through coordination with this program assisted in the development of

the basic organization and content of both the Applications Manual and

the training program.

316
THE APPLICATIONS MANUAL

An Applications Manual was designed and developed to serve as the

nucleus of the training program and as an educational text for use by

building officials during the workshop program as well as a working

reference guide to be used later on the job. In its final form, the

manual contained over 100 pages of charts and tables incorporating

data pertinent to code enforcement in the eleven different climatic

regions in New Mexico. The following, from the manual's table of

contents, briefly summarizes its organization and content.

INTRODUCTION

What This Applications Manual Is All About, and Why?

Some important questions are discussed as to the need for this course and fulfillment of the State law, the origin and nature of the

building code, background knowledge required to apply the new code

fairly, an appreciation of the variety of factors to be considered in

the overall appraisal of energy conservation materials and techniques

,

and the role of the building official in the enforcement of the new

code.

Part I

What You Need To Know About ENERGY FUNDAMENTALS

Introductory remarks about energy and heat transfer presented for

general knowledge rather than as an exhaustive treatment with emphasis

on an appreciation of the problems that may be met when considering

the many factors of energy conservation in buildings .

.

. including

heat measurement, the flow of heat, heat loss, fundamentals of human

comfort, and factors affecting energy consumption in buildings.

Part II

What Does THE CODE Mean?

A presentation of detailed information of the content. Chapter 52

of the Uniform Building Code, intended to provide the building official

with all aspects of the code, how the various sections work together

through the specific requirements of the building envelope, the mechanical systems, and the electrical systems regulated by the code.

317
Part III

APPLICATIONS of The Code

After learning the basics of energy fundamentals and the details of

the energy conservation code3 how is the knowledge applied on the job?

Three elements of construction are tied together in this Fart: the

builder needs to know what is required of him for code compliance; the

plan checker needs to know all elements of acceptable code compliance;

and the field inspector needs to know what he is looking for on the job

and to relate the information on the plan to the construction site.

APPENDICES

Reference Materials And Aids

A collection of charts^ tables, schematics, drawing details, and

checksheets provided to aid the builder, the inspector, and. the plan

checker in working out whatever calculations may be required for field

use of the knowledge gained in energy conservation construction.

As mentioned previously, the unique feature of New Mexico's

approach to implementing Chapter 53 involves the concept of "Effective

U Values." These values, unlike traditional steady-state U values,

take into account the large diurnal temperature differences and the

high incidence of solar radiation relatively unique to New Mexico.

This concept significantly alters more established concepts concerning

the thermal performance characteristics of building materials commonly

used in New Mexico.

On a limited basis, the Construction Industries Commission has

authorized the use of effective U values in determining code

compliance. Individual pages tabulating effective U values for a number of wall types were included in the Applications Manual. Since

research continues, and many more pages are contemplated, the manual

was produced in loose-leaf form for ease in updating. In addition,

manuals were numbered and accounted for by owner to facilitate the

updating process.

DEVELOPMENT OF THE TRAINING PROGRAM

Since the Applications Manual was designed to form the basis for

the training program, a critical effort centered around the

presentation. It was determined early in the program that, excluding

administrators and senior supervisors, building officials may be

divided into two job categories:

1. Plan Checkers -- officials who review and approve plans for

code conformance prior to issuance of a building permit, and

318
2. Field Inspectors -- officials who inspect actual

construction to assure compliance with plans and codes.

Of the roughly 120 building officials in New Mexico,

approximately 15% are Plan Checkers. Plan Checkers typically have

completed 16 years of education and have a Bachelor's degree in

Architecture, Engineering, or some similar field. Field inspectors

constitute the remaining 85% of building officials. Field inspectors

typically have completed 12 years of education and have a high school

diploma. Based upon this and other information furnished by the

Commission, it was determined that the training program should have

the following characteristics:

1. It should be structured as a workshop requiring a high level

of active participation by the building officials.

Interaction between the officials and the instructors was to

be encouraged at all times. Sample problems directly

related to the officials' specific role in code enforcement

should be presented and solved during the workshop.

2. The presentation should employ a wide variety of film

strips, slides, and other visual aids to illustrate the more abstract concepts of energy fundamentals and to lead the

officials step by step through the various mathematical

calculations required by the code.

3. The portion of the workshop dealing with the actual

application of the code should be divided into two sections:

one for Plan Checkers concentrating on their role of

reviewing plans for code conformance, and one for Field

Inspectors concentrating on their role of conformance of

construction to the approved plans and the intent of the

code

.

4. The overall program should be conducted in a single

eight-hour day. Although eight hours is probably short of

the time needed to fully absorb the material, it represents

the maximum amount of time the average building official,

given his normal workload, can spend away from his job. The

approximate subject-time allotment of the workshop was as follows

Introduction 3/4 hours

Part I - Energy Fundamentals 2 1/2 hours

Part II The Code 1 1/2 hours

Part III Application of the

Code 2 1/4 hours

319
INSTRUCTORS

The selection of instructors for the program was recognized as critical since the material to be presented was comprehensive and

complex. The ability to relate to building officials and to establish

a comfortable rapport with them was important, and this, together with

the fact that the program was largely vocational in concept, suggested

that the instructors should have a strong vocational education

background. The vision of the university professor lecturing down to

the building official seemed to guarantee a turned-off audience.

Therefore, the Albuquerque Technical Vocational Institute was contacted and arrangements ultimately were made for the release of two

instructors to team-teach the workshop.

Both individuals have architectural degrees and 4 to 5 years

experience as vocational education instructors. In addition, both

were familiar with building codes and both had interacted with

building officials in a variety of situations. This combination of

qualifications fit the requirements well and proved to be extremely

successful

MARKETING THE TRAINING PROGRAM

Planning for the implementation of the program involved such

matters as the promotion of the program, the selection of appropriate

facilities in which to conduct the workshops in each of the five

designated cities, and the scheduling of the workshops in those

cities.

Promotion of the program to ensure maximum attendance was suggested by the Institute and conducted by the Construction

Industries Commission. The Commission first arranged for the Governor

of New Mexico to send a letter to the mayors of all municipalities

urging them to release their building officials to attend the training

program. The Commission followed this letter with one of its own addressed to individual building officials to strongly suggest and

request their attendance. In addition, an announcement was made in

the monthly newsletter of the New Mexico Chapter of the American

Society of Building and Construction Inspectors as well as other

publications throughout the State including the local newspapers.

This marketing approach was extremely successful as reflected in

the 97% attendance record.

FACILITIES

The five cities in which the workshops were to be held were located geographically throughout the State for the convenience of the

building officials. The five separate workshops assured minimum

commuting time for officials and, if necessary, the opportunity to

attend an alternative workshop at a more convenient date and location.

320
The amount of time allocated for the preparation of the

Applications Manual and the development of the training program made

it apparent from the outset that the workshops should be scheduled as late in June as possible. The schedule called for workshops in Las

Cruces and Roswell in the southern part of the State in one week,

Santa Fe and Farmington in the northern part of the State the

following week, and Albuquerque, the largest city, on the final

Saturday of the month. Because of the level of construction activity

in Albuquerque, the Superintendent of the Building and Inspection

Division for Albuquerque opted to hold the workshop on a Saturday so that the Division would not have to miss an entire working day. This

schedule also provided the Institute the opportunity to conduct

planning and evaluation sessions with the instructors on days between

workshops

.

In view of the desirability of holding the building official

group together for the entire workshop day, it was determined that

motels or inns with integrated restaurants were the most appropriate

facilities in which to hold the workshops. Building officials and

instructional staff were released in a group to the restaurant for

lunch and tended to remain on the premises until resumption of the

workshop. In this manner, an orderly transition from the morning to

the afternoon was assured.

TRAINING PROGRAM EVALUATION

In total, the workshops attracted over 97% of building code

officials throughout the State, and their reaction to the program was very enthusiastic.

At the conclusion of a workshop, each building official was asked

to complete a course evaluation giving his opinion of the categories

of materials presented and the methods of presentation. Comments and

suggestions were also solicited. In most instances, the evaluations

were returned unsigned. Approximately 90% of the officials rated both

categories "Very Good" to "Excellent" (4 to 5 on a 5-point scale)

.

The most critical comment offered concerned the length of the

presentation. Many officials felt it was too short. This reaction

was not unexpected, and funding has already been approved to conduct

the follow-on workshops at six-month intervals through June 1978.

The consensus of Construction Industry Commission officials and

administrators is that the workshops contributed greatly to the

knowledge of building officials and were a stimulating experience for

them. They believed that building official participation in the

workshops will result in fewer job-related problems and better code

enforcement.

SUMMARY

In conclusion, from all indications, the overall program has been

a resounding success. There is little doubt that this stems in part

321
of the fact that it filled a specific need for timely energy

conservation information as well as fulfilling the mandate of public

law. Many workshop participants pointedly expressed gratitude and

appreciation for the training and stated that it may have been the

first time they had seen a government organization do something right.

The success of the training program has prompted the initiation

of another project to present the same course to building contractors,

architects, and engineers. Such a program is already underway.

322
IMPACT OF STATE MANDATED THERMAL EFFICIENCY STANDARDS ON COUNTIES

by

Sue Guenther and Archie Twitchell,

National Association of Counties Research Foundation,

Washington, D. C.

Nineteen States have adopted energy-related building regulations

since the 1973 Arab oil embargo, but there is considerable variation

among the States according to performance and prescriptive criteria,

mandatory and voluntary regulations, etc.

The remaining States will soon be adopting thermal efficiency

codes as part of their State Energy Conservation Plans, and the

Department of Housing and Urban Development is currently developing a national standard for new buildings.

Hundreds of counties have been required to enforce the existing

State-mandated codes, and many hundreds more will become involved in

the near future.

The National Association of Counties Reasearch Foundation studied

the effects of State-mandated thermal efficiency codes on five

counties. We found that those codes requiring only a minimal amount of

insulation and double glazing for windows appeared to present no major

legal, political, operational, or financial problems for counties.

Experience with more sophisticated codes is limited.

Key Words: Buildings; counties; energy conservation; enforcement;

insulation; regulations; standards; State legislation;

thermal efficiency.

323
INTRODUCTION

The purpose of the study was to determine what effect on counties

the implementation of State-mandated Thermal Efficiency Codes (T.E.C.)

has had, if any.

When this study was undertaken (July 1976), there were nineteen

(19) States with authority to regulate energy use through the

regulation of the design and the construction of new buildings.

In sixteen States a statewide building code was a vehicle for

energy regulations:

Three States have energy regulations separate from statewide

building code authority: California, Nevada, and New York.

From among these, four States were selected from among which four

counties would be chosen. The criteria used in the selection process

were

1) Has the State made progress on energy conservation

standards?

2) Representation of different climatic and geographical

regions?

3) Amount of construction activity?

A) Type of construction activity (residential: wood,

frame, brick, other)?

5) Representation of varying population sizes and

characteristics

6) Sophistication of the enforcement system?

7) Local authority and interaction between the States and

counties?

8) Energy consumption patterns?

Connecticut

Florida

Idaho

Massachusetts

Michigan

Minnesota

Montana

New Mexico

North Carolina

New Jersey

Ohio

Oregon

Rhode Island

Virginia

Washington

Wisconsin

324
The States of California, Minnesota, North Carolina and Oregon

were selected for study.

The criteria used to determine which counties should be studied

follows

1) Was the county implementing a State thermal efficiency

code?

2) Was sufficient building activity occurring to provide

experience and a data base?

3) Did the county have a professional staff willing to

participate in the study?

4) The urban-rural mix, size of county, growth rate and

any unique features were also considered?

The five counties selected for study were:

Lane County, Oregon; Mecklenburg County, North Carolina;

Montgomery County, Maryland; Sacramento County, California; and

Washington County, Minnesota.

Montgomery County, Maryland, was added to the list of counties to

study because of their effort to undertake a local T.E.C. in the

absence of a State code.

Since the majority of States do not have either a State energy or building code, a free-standing process might be of interest to a large

number of counties in the country.

The methodology of the study was:

a) Background information: familiarization with Federal

energy law; energy code issues (prescriptive vs. performance) ; status of State codes and background

gathering on the roles of Federal and State energy

agencies

.

b) A task force composed of five elected and five

appointed members reviewed the proposed project

activities. They also reviewed and approved the final

report.

c) The field study (data gathering) involved reviewing the

State and local energy codes, and interviewing numerous

State and local officials involved with energy.

Interviews with builders, lenders, architects, and

citizen committee members were also conducted.

325
d) The data was analyzed to determine what effects were

reported. They were grouped into four broad

categories: legal, political, financial and

operational effects.

e) A draft report was prepared which reported each of the case studies and the conclusions drawn from them. The

task force reviewed and approved the report on March 3,

1977.

It became apparent in the course of the study that State mandated

thermal efficiency codes should be analyzed in the context of the

total situation because a number of factors external to the T.E.C.

affect the type and degree of impacts. For example, the particular

climate of the county affects the number of heating/cooling degree

days and the energy consumption patterns. It became apparent that the

degree to which the population believes a need for energy conservation

exists appears to affect the timing and extensiveness of the energy

legislation. Consequently, the energy situation in each State was examined to reveal supply and consumption patterns and shortages, if

any.

The energy situation affects the economic health of the State and

the county. Without adequate supplies of energy, growth cannot occur. Counties in a growth situation respond to demands for new subdivisions

through their planning function. New homes mean more streets and

highways, water and sewer system growth. Increased gasoline usage

brings additional per capita excise tax revenue to counties.

Franchise taxes on utilities provide added income. As patterns of

growth expand over a long period of time, counties become accustomed

to increased increments of revenue and expenditure.

Without adequate energy supplies the growth situation of the

counties would change dramatically.

The growth experience of each county in the area of single family

homes is presented below:

Number of Single Family Housing Permits

1970 - 1976

1970 1971 1972 1973 1974 1975 1976

Sacramento 2269 2712 2914 2428 2990 3500 5490

Lane 569 680 675 574 476 481 609

Washington 1261 1015 1038 980 1416

Montgomery 2685 3006 3238 3265 1730 590 1178

Mecklenburg 3341 5198 7660 8088 1966 1628 2140

326
The energy conservation codes examined are both prescriptive and

performance codes. That is, if the builder produces component parts

(walls, floors and ceilings) which meet the thermal transmittance

values of a prescriptive code the building is presumed to achieve the

desired thermal performance. A performance code permits the builder

to vary the thermal resistance of the component parts so long as the

desired overall thermal performance is achieved.

The chart on page 328 compares the codes of our States and Montgomerv

County (Proposed) to the draft Model Energy Conservation Code. (ERDA,

January, 1977.)

The model code is based on the ASHRAE 90-75 standard. The

comparison reveals important differences between the model and the

codes

.

The codes are divided into two categories:

a) First generation codes refer to the initial energy

conservation codes adopted by California, Oregon and

North Carolina. Their scope is limited to residential

buildings and they each establish standard construction

practices as the minimum. They address the thermal

efficiency of the building envelope, i.e., wall,

ceiling, floor and window components. A major revision

of the energy code is under consideration in each of

these States.

b) Second generation codes address a different magnitude

of concern. They apply to all building, and establish

minimum standards for the building envelope. They also

address the environment of the building, i.e., its

relationship to the sun, wind, shade trees, etc. The

performance capability of heating/ cooling equipment,

water heaters, manufactured doors and windows--the

operating systems--are addressed. The standards

applied may exceed the current practices of both

builders and manufacturers.

A major difference between the model code and the codes of the

three States and Montgomery County is the 70 degrees or lower design

temperature for winter compared to 72 degrees for the model code.

(North Carolina has no specific standard in its code). The lower

design temperature saves fuel at the rate of approximately 3 percent

per degree.

The report by Arthur D. Little Company (July, 1976) asserts that the

ASHRAE 90-75 Standard as applied to residential buildings produces

approximately an 11 percent energy savings. The same report estimates

a 50% energy savings for office buildings constructed according to the

ASHRAE 90-75 Standard. In each case the initial per square foot cost

for building construction is reduced.

OVERVIEW OF STATE THERMAL CODES

327
COMPARISON: MODEL CODE WITH THE CODES OF THE FIVE COUNTIES STUDIED

FIRST GENERATION CODES SECOND GENERATION CODES

ITEM MODEL CODE CALIFORNIA NO. CAROLINA OREGON 'MARYLAWO* MINNESOTA

Scope

Design Parameters

Alternative

analysis sys- tem pennited

Thermal trans- mittance values

-ceilings

-walls

All new buildings

w/ human occupancy

72° winter

78° summer

yes

values of each component related

to no. of degree

days

Inhabited residential structures

70°

78° winter

suiiner

yes

.05

.OS

1 & 2 family; and multi-family bldgs

3 stories or less

in height

yes

.05

.08-. 17

Residential bldgs

3 stories or less

in height

70° winter

yes

.05

.08

All conditioned

buildings

70°winter

78° summer

yes

.05

.04 residential

All condi- buildings

incl. re- modeling and additions

68° winter

78° summer

yes

.05

.17

-floors

(slab on grade)

Fenestration no area limits

Uo varies w/S

of fenestration

.0-.08

no area limits

.12-. 08

no limits; where fenestration ex- ceeds 202, Uo must equal .65

.20-. 09

no limits; where

fenestration exceeds 20%, Uo must equal .70

varies w/const.

no limits; Uo value declines

as fenestration increases

no area

limits but heat trans- mission li- mited to 120BTU/hr/

sq. ft.

Condensation

Control

Air infn'tratlon Ansi Stds.

vapor barrier vapor barrier

weather stripping none required ASTM E-283

Std. applies

specified

ASTME-283

Std. applies

Limitation on capacity of heating/cooling

systan

design require- ments specified

none none specifies mini- mum COP** equipment limited

to-. a) heating 115% of design

capacity

b) cooling lOOS of design

capacity

Workmanship

standards

Building Orientation to sun

yes none yes

yes

Source: "Draft Energy Conservation Amendments" by Charles Rand, Assistant County Attorney, December 1976

** Coefficient of Performance

328
The combination of condensation, air infiltration and workmanship

determine to a large extent the thermal ef f ectivemess of a building.

No standard has been adopted for condesation control although two

States specify vapor barriers and the presumption is they are adequate. In the first generation code States of California, North

Carolina and Oregon, only one (California) has adopted standards

limiting the air inflow per linear foot of crack. North Carolina

requires weather stripping only and Oregon establishes no standard.

Workmanship standards are mentioned only in North Carolina and in

neither of the other two first generation States.

By contrast the second generation codes of Maryland and Minnesota

specify air infiltration standards. Maryland is silent on condensation and workmanship while Minnesota is specific in

legislating in both categories.

Although the thermal transmittance values vary among the State

codes, the degree of variation is low considering the extreme

difference among the weather conditions of the different counties.

For example, Sacremento County has 2800 degree days annually whereas,

parts of Lane County exceed 7000 degree days.

Fenestration (windows) is the greatest source of hat lost in the

building envelope, yet all of the codes are premissive to the extent

that they do not limit te amount of fenestration rather they require

double glazing when fenestration exceeds 20 percent of the wall or floor area.

WASHINGTON COUNTY, MINNESOTA

The Minnesota Energy Agency reports energy consumption for 1975

and projects usage in 1985 as follows:

Energy Consumption 1975 - 1985

(Figures in Trillion BTU)

Source 1975 Percent 1985 Percent

of total of total

Petroleum 485 44 669 41.0

Natural Gas 326 29 281 17.3

Electricity 111 10 123 7.6

Coal 183 17 553 34.1

Total 1105 100 1626 100

The Agency's conclusions are:

a) Petroleum will maintain its relative share of the

market.

329
b) Natural gas will be in short supply and occupy a declining share of the market.

c) Electricity cannot bear a greater proportion of the

energy load because the long lead times prevent

generating capacity from coming on line by 1985.

d) Coal consumption will increase significantly.

Considerable shifting from natural gas to coal by

industry is expected.

e) The total BTU's consumed will increase from 1105

trillion in 1975 to 1626 trillion in 1985. A 47%

increase

Some important assumptions are made:

a) Canadian crude oil which made up 25% of the total

energy supply for the State in 1975 will no longer be

available. The Agency believes either Alaskan or Arab

oil will be available and can be delivered. However,

existing capacity in the pipelines entering the State

are not adequate to serve 1985 needs and it is assumed

an adequate delivery system will be available.

b) Since natural gas will decrease in total volume,

industry will convert to another fuel. Only coal

appears to be available. Whether adequate

environmental standards can be met is not known.

c) A 47% increase in consumption for the decade

1975 - 1985 is projected. The assumptions are:

1) fuel will be available in sufficient quantity,

and,

2) fuel prices will not be so high as to divert

growth to lower energy cost areas of the country.

Washington County is in the growth path of the Minneapolis - St.

Paul metro area. The building department work-load is generated

mainly by the volume of new building activity created by the growth

phenomenon. If growth is energy dependent and if the state's supply

projections prove high, the current demand for new buildings in

Washington County could slacken.

The Minnesota Energy Code is the most complex and far reaching of

the five states studied because:

a) It applies to all buildings.

b) It is a minimum and a maximum code - none of the other

codes are both. The minimum aspects relate to thermal

330
efficiency standards while the maximum apply to

equipment sizing and use of energy in humidification,

dehumidification, and lighting.

c) It is both a performance and a prescriptive code. The

builder may choose the Alternate Energy Analysis

Method. The amount of staff time required is much

greater if the performance approach is selected.

d) The code provides for local enforcement.

e) The number of items is more extensive than the other

codes

.

f) The code permits the application of an orientation

standard for siting buildings.

The effects of the Minnesota Code on Washington County are assessed below.

EFFECTS OF CODE

Operational Effects ;

The County Building Official began accepting responsibility for

the Minnesota Energy Code during its preparatory stages. The Building

Official attended meetings, hearings, read drafts, commented and

otherwise participated in the code preparation.

Subsequent to passage, the Building Official established

administrative policies governing implementation by:

a) defining plan check and building inspection work;

b) creating a work flow system;

c) controlling the quantity and quality of work through a checklist system and an energy evaluation form;

d) determining that training was needed and designating

those who should receive it.

The work of the Washington County plan checker is more difficult

than in other States where plans are reviewed only for the appropriate

"R" value of insulation. Specifically he must:

a) determine and/or review calculations of areas and

thermal transmittance values for exterior walls,

roof-ceiling areas, windows, doors, floors over unheated spaces, air infiltration and water vapor

condensation, based upon the minimum provisions of the

Code;

331
b) perform a site and shape analysis;

c) check for code conformance of heating, ventilation, air

conditioning systems, service water heating, electrical

distribution and lighting systems under the maximum

provisions of the code;

d) be capable of using the Alternate Energy Analysis

Method.

The building inspector's task is also different as he:

a) conducts on-site inspection to ensure that insulation

is properly installed (foundation, walls, ceilings);

b) checks to see that manufactured components such as windows, doors, skylights, etc., are as specified in

the plans and are correctly installed;

c) determines that the heating equipment operates within

115% of the design standard and that the air

conditioning does not exceed the design standard;

d) makes observations of air infiltration and

fenestration.

Washington County implementation costs for the Minnesota Energy

Act are estimated as follows:

a) initial administrative work cost about $500;

b) initial training costs were $1,000 for the first year

and estimated at $500/year thereafter;

c) plan check time has increased about 45 minutes per set

of plans. At an hourly rate of $7.25/hr. the average

cost per set of plans is $5.43. Gross first year costs

are about $7,700 for 1416 dwelling units;

d) inspections require about 120 minutes per house

including travel time. Cost is estimated at $15 per

house and $7,500 total for the year;

e) total impact equates to one full-time staff position

equivalent in the estimation of the Building Official.

Political Effects :

The Chairman of the Board of County Commissioners can discern no political effects from the Minnesota Thermal Efficiency Code. The

affected public responded to interview questions as follows:

332
a) builders accept the code as fair and complete,

interpretation by Administrators has also been fair;

b) architects accept the code and note that no official

position was taken from their State Association. The

flexibility provided by the Alternate Energy Analysis

method Is respected. They point out, however, the code

as T.T>;it:ten requires a "double design," i.e., a standard

component design plus the alternate. Thus, it is

likely the systems analysis approach will not be widely

used.

Builders, architects and public officials report high public

acceptance of the code. The fact that the State brought affected

parties together to help write the code seems to have increased the

acceptance level.

Legal Effects :

The County Attorney reports no legal actions involving thermal

efficiency standards. He notes, however, that a State law imposes a requirement to act on the part of county officials and a failure to

act could create some legal consequences.

Because the Alternate Energy Analysis Method allows flexibility

in designing and constructing buildings and because the affected

parties believe administrative interpretations have been fair, little

incentive for legal action exists.

Financial Effects :

The principal economic effects of the thermal efficiency code are two-fold: somewhat higher capital costs for the home buyer and higher

administrative costs for the county.

A builder of quality homes believes the State requirements have

not increased costs to him because his construction practices exceed

requirements adopted. A builder of more moderately priced homes

($25,000 to $30,000) finds his insulation costs increased

approximately $150 per home. The builders report the code is

cost-effective

.

The public costs were examined in detail by the Building Official

and he reports

The public costs for current administration, training,

forms, overtime, approach $15,000 per year for up to 1,500

homes. No budget increases occurred during the first year

due to a lack of actual experience data. For the second

year of the program, one additional staff position was

333
added, at approximately $15,000 per year, directly

attributable to energy code enforcement.

Existing fee schedule, which was originally established in

1972, was not increased during first year of program;

however, based upon the experience of the first year, the

fees are projected to be increased during the second year,

only in part due to the impact of energy code requirements.

Fee increases related to Energy Code are anticipated to

average $20.00 or less per single family dwelling.

REFERENCES

Minnesota Energy Agency, "Minnesota's Energy Situation, A Biennial

Report to the Governor," January, 1976.

Minnesota Energy Agency and Building Codes, "Implementation of a Statewide Energy Code for Buildings," August 27, 1976.

Minnesota State Regulations; SBC 60001-6013, "Energy Conservation in

New Buildings, Additions and Remodeled Elements of Buildings."

MECKLENBURG COUNTY, NORTH CAROLINA

North Carolina has been a pioneer in the field of State building

regulations. The first building laws were passed in 1903. The

authority to promulgate a statewide building code was delegated in

1933 to a Building Code Council composed of citizens. In 1957, the

Council adopted a policy of permitting local variations only if

"absolutely necessary" in an effort to make the code more uniform

throughout the State. The Council adopted Chapter XXXII, Building

Insulation Standards in September 1974 and made them effective as of

January 1, 1975.

IMPLEMENTATION EFFECTS

Operational Effects :

On January 1, 1975, Mecklenburg County began enforcing the North

Carolina Building Insulation Code for all residential dwellings of

three stories or less in height. In the past two years, the code has

been applied to 3700 new residential units. The administrator of the

county building department interprets the North Carolina Code as both

a prescriptive and performance code.

A prescriptive code requires the builder to meet a specific

thermal transmittance (Uo) value for the component of the building

334
envelope. A performance code permits the Uo values of the component

parts to vary, providing the equivalent overall thermal performance is

achieved

.

The county decided on a series of actions in order to implement

the code:

a) job descriptions were amended to include a thermal

element in the plan check and site inspection

functions

;

b) work flow was organized;

c) a check list of activities for the plan checker and

building inspector was developed to control work

quality.

The energy code did not require any reorganization of the

Building Inspection Department. The roles of the electrical,

mechanical, and plumbing divisions did not change.

The implementation of the State Insulation Code has two principal

effects on Mecklenburg County:

1) the plan check process required 10 additional minutes

per residential building;

2) the site inspection process required 15 more minutes

(if the insulation was not ready when the framing

inspection was conducted an additional hour for the

return inspection became necessary)

.

The added work did not require additional staff although some additional training was necessary the cost of which was absorbed

in-house. The management and operation of the county building

department has been minimally affected by the State Insulation Code.

Political Effects :

The chairperson of the County Commission finds high public

acceptance of the county's involvement in numerous energy conservation

activities. She reports no negative repercussions from the county's

enforcement of State Mandated Building Insulation Standards.

Financial Effects :

The enforcement of State Building Insulation Standards has had a minimal fiscal effect on the county. Revenue to the county has not

increased. Permit fees have not changed. Total budget costs have not

increased. The added work load has been absorbed without changes in

335
staffing patterns. No capital outlays have been requested. Overhead

cost increases have been minimal, i.e., a few hundred dollars for

training and printing new forms has been absorbed in the current

budget

The additional time required to process plans (10 minutes each)

and perform site inspections (15 minutes normally) has been absorbed

by current staff.

Building activity has declined from a high of 8,088 new single

family units in 1973 to 2,140 in 1976 due to changing economic

conditions, not thermal standards.

The recent history of rapid fluctuation in housing starts has

permitted the Building Department to allocate time to other

energy-related matters such as energy management of county buildings,

a citizen's survey committee and demonstration projects, in addition

to the enforcement of the energy code.

Figure I illustrates the changing annual volumes of single family

housing starts between 1970 and 1976.

FIGURE I

MECKLENBURG COUNTY SINGLE FAMILY HOUSING STARTS

1970 - 1976

1000

O I— CM "^j- to KO 1^ I

CTl CT> CT» CT>

When the county recovers its previous growth rate, more staff will be

required to handle the same number of permits because of the time required

by the thermal code. However, at the present time, the fiscal impacts on

the county budget are deferred because of factors external to the state code

336
The private costs are not deferred. Builders report the selling

price of a "typical" three bedroom house has increased from $38,500 in

1974 to $42,500 in 1976. Approximately 10% of the $4,000 increase is

attributed to energy-related equipment such as storm windows, improved

heating units, and additional insulation. But, builders report that

energy improvements are cost-effective because the increased costs are returned through lower heating and cooling bills within a five year

period according to a cost-benefit analysis. The impact on the cost

of homes varies. The "budget" home may not have been constructed to

the standards of the new insulation code. A new home may cost about

$200 - $400 more.

No delays in the plan approval process have been experienced by

builders. The latter is confirmed by the Building Official. One

builder reports construction delays are caused by the State insulation

code. He says a slab-on-grade foundation inspection can now require

two additional days. Insulation at the foundation parameter can mean

a one day delay. If a crawl space is built instead of a heated

basement, a delay of one day can occur. No estimate of the dollar

cost of construction delays is available. The delays are disputed by

the County, the County Engineer and Building Official.

A lender reports the loan quality of buildings is affected by

insulation standards:

a) a loan request would be adversely affected by the

absence of insulation;

b) a high degree of thermal efficiency enhances the loan

quality particularly if the home is all electric;

c) financial capacity of the borrower remains the dominant

criteria for granting loans.

This lender reports that only a few years ago the ability of the

borrower to carry the principal and interest was the determining

factor for lenders. Today the cost of operation is a consideration.

This lender will permit monthly principal and interest payment to

exceed 25% of monthly income and may range in the 27 - 28% area.

Legal Effects :

In the County Attorney's opinion:

a) the county has incurred no additional liability from

the enforcement of State code;

b) the prescriptive and performance characteristics of the

code have not increased the county's legal liabilities

for acts performed under the code.

337
Summary :

The County experienced no difficulty in the start-up phase of

implementing the new North Carolina Building Insulation Standards.

Its experience with 3,700 single family housing units built under the

code has been:

a) No adverse political and legal ramifications.

b) Lenders recognize the value of thermally efficient

buildings and are adjusting loan practices accordingly.

c) Financial effects are:

1) Cost of previously uninsulated and under-insulated

homes has increased $200 - $400.

2) The administration of the code has caused no delays in the plan approval process.

3) Construction delays are alleged due to site

inspection related reasons. The county disputes

the allegation.

4) The code requirements are cost effective.

d) The operational effects are minimal. The additional

work has been absorbed by existing staff.

NORTH CAROLINA REFERENCES

The North Carolina Department of Military Affairs, Energy

Division (the responsible agency) supplied the following documents:

1) North Carolina's Energy Outlook for 1975 ; (February, 1975)

2) North Carolina's Energy Outlook for 1976 ; undated

3) Typical Energy Cost Increases for the Raleigh Area and

Some Factors Affecting the Increases ; October, 1974.

4) Energy Consumption in North Carolina Manufacturing

Industries; 1972; (June, 1975)

5) North Carolina Petroleum Distribution ; (March, 1975)

6) North Carolina Inter-Agency Task Force Report on Natural

Gas(November, 1976)

7) North Carolina Building Code, Volume I, General Construction

plus amendments adopted January 1, 1967, then January 1,

1976.

338
LANE COUNTY, OREGON

Oregon is one of sixteen States with energy regulations in effect

at the present time. The Oregon Building Code is a statewide code

based on the Uniform Building Code (UBC). The recommended provisions

for an energy code are found in Chapter 53 of the UBC which the State

modified and limited to residential structures.

The energy situation in Oregon has been analyzed by the Oregon

Department of Energy. Data pertinent to this study is summarized

below.

Four trends in residential energy consumption are depicted in

Table I:

a) the average annual rate of growth is 5.7 percent per year

for total residential consumption;

b) petroleum declined from 46.9 to 21.6 percent of the

residential market;

c) electricity grew from 38.1 percent to 49.8 percent of the

residential energy market replacing petroleum as the prime

energy source.

TABLE I RESIDENTIAL ENERGY CONSUMPTION

YEAR TOTAL

(10l2 BTU) PETPOLEUM*

lO^^BTU % ELECTRICITY

10 BTU % NATURAL

lOl^BTU

GAS

%

1962 53.5 25.1 46.9 20.4 33.1 3.0 15.0

1963 58.7 27.9 47.5 21.7 36.9 9.1 15.6 1964 66.0 31.2 47.2 23.6 35.3 11.2 17.0

1965 64.7 23.9 44.8 24.1 37.3 11.6 18.0 1966 67.1 28.2 42.1 25.7 33.3 13.2 19.7

1967 67.6 26.6 39.4 26.7 39.5 14.3 21.1

1968 71.7 27.1 37.8 28.6 39.9 16.0 22.3 1969 78.1 27.6 35.3 31.7 40.5 18.8 24.1 1970 77.9 25.6 32.9 32.7 41.9 19.6 25.2 1971 85.0 26.5 31.2 36.1 42.4 22.4 26.3

1972 86.7 25.8 29.7 37.8 43.6 23.2 26.7

1973 84.1 21.9 26.0 39.1 46.6 23.1 27.4 1974 80.0 17.3 21.6 39.9 49.8 22.3 23.5

*the rasldentlal/commercial Petroleum is divided 2/3 to residential customers

and 1/3 to commercial ctistomers.

SOURCE: Oregon Depcurtment of Energy. "Future Energy Options." July 1, 1976, p. 46.

339
The trends are dramatically illustrated by Figure 2 below.

FIGURE 2

Changing Composition of Energy Consumption

in the Residential Sector

Percent of

Residential

Energy Market

1%)

Source: Oregon Department of Energy "Future Energy Options" p. 47

340
Data about the type of fuel used in dwellings is available for

Lane County.

TABLE II

FUEL USE IN DWELLINGS BY TYPE

ELECTRIC GAS OIL HARDFUEL TOTAL

Incorporated 15,545 4,415 6,305 9,023 27,188

area

Unincorporated 9,571 2,141 4,419 2,627 18,758

area

Total 25,116 6,556 10,724 3,550 45,946

Two conclusions are drawn from a comparison between the State and

Lane County consumption patterns:

a) natural gas is less frequently used as a fuel source in the

unincorporated areas. Population densitites often do not

warrant the installation of gas pipelines;

b) the type of fuel used is not otherwise significantly

different (except the State does not report hard fuel).

The types of fuel used affects the kind of inspection provided by

the county, i.e., an electrical inspector examines the installation

when it is the heat source. A mechanical inspector examines the

installation otherwise. There is no discernable effect on the energy

conservation code nor on insulation requirements. The County Building

Inspection Department began enforcing the State Energy Code in June,

1976. The Building Code did not require insulation or other thermal

efficiency measures prior to that date.

The county applies the thermal efficiency standards as both a performance and a prescriptive code as provided for by the State law.

The county has the staff expertise to implement the performance

procedure if the builder selects that method.

The implementation of the State thermal standards is a two-step

process in Lane County. First, residential building plans are checked

by building inspectors, i.e., they determine if the required

insulation with the appropriate "R" values is shown on the plan. Two

copies of the plan are similarly marked. One is submitted to the

contractor and the other is used for reference by the building

inspector. An on-site four-step inspection is made. Foundation,

framing, sheetrock, and final inspections have been customary under

the State code. The insulation inspection occurs during the framing

inspection.

341
The amount of time required for thermal inspection and plan

checking in Lane County has increased. The Chief Building Official

estimates the thermal check of residential plans requires an additional 15 minutes. Field inspections demand little time as only a visual observation of the insulation and the workmanship is necessary.

Organizational Effects :

The organizational impacts resulting from the enforcement of the

State code are:

a) no reorganization of the building department has been

necessary;

b) no new staff has been added;

c) no changes in the work flow or other procedures have

been needed;

d) no budget increases have occurred.

The Lane County Building Department conducted in-house training

seminars and participated in State-sponsored training programs for the

purposes of acquainting plan checkers and inspectors with the State

thermal efficiency requirements.

Economic Effects :

Oregon's Energy Conservation Standards for residential properties

has created minimal public and private costs. The home builder's

report a capital cost increase of between $100 and $200 per house.

Since the typical three bedroom house is reported to cost about $4,500 more in 1976 compared to 1974, insulation is not a major factor in the

price rise. The new code has not caused either construction delays,

processing costs or loan costs. Therefore, only the cost of added

insulation has been passed on to the purchaser. Housing is reported

to be scarce in Lane County, consequently, thermal efficiency is not a consideration in the housing market.

The economic impact on the public agency is near zero. There

have been no detectable shifts in the location of new residential

buildings. Therefore, revenue generated by building activity has not

shifted between jurisdictions. The fee for building permits remains

unchanged, i.e., $150-170 per 1400-1500 square foot single family

unit.

The public costs for servicing a permit are:

a) $1.67-2.23 per single family permit; or

342
b) a total of about $1,000+ per year for the county at an average of 500 new units per year; and

c) training costs estimated at $500.

The County budget has not increased because the work load has

been absorbed by existing staff.

Political Effects :

The Chairman of the County Commission reports:

a) State mandated thermal efficiency standards have

imposed no additional burden on the County Commission;

b) political capacities have not been affected;

c) the climate for action in the energy conservation arena

is positive;

d) the county has assumed a leadership role in the energy

conservation field.

Legal Effects :

No law suits nor any legal inquiries about the State Energy Code

have occurred since its inception. The Assistant County Attorney

reports no legal impacts are likely as the only exposure comes from a failure to implement the State code as required and that is highly

unlikely.

OREGON REFERENCES

Future Energy Options for Oregon , Oregon Department of Energy,

July 1, 1976.

Oregon Revised Statutes , Chapter 456, Sections 750-885, Lane

County

.

Energy Conservation and Management Program , A.J. Mandel; Lane

County (6-76).

Resource Recovery Facility (R.F.P.), Lane County (2-76).

Public Service Building: Architects, Uthank, Seder, Peticia

(12-76).

343
SACRAMENTO COUNTY, CALIFORNIA

The California legislature created the State Energy Resources

Conservation and Development Commission in 1974 for the purpose of

recommending energy policy to the legistature. The Commission is also

empowered to adopt energy conservation regulations. The Energy

Insulation Standards for Residential Buildings were promulgated as administrative regulations on December 23, 1975. California does not

have a statewide building code.

Energy Situation:

The Commission's Energy Policy Committee prepared a Policy

Overview Report for the Legislature (October, 1976) which draws three

conclusions

1) national energy policy is: a failure, technically

unachievable and sloganeered;

2) State Energy Policy has floundered because deep-seated and

fundamental disagreement exists about what, if anything,

needs to be done;

3) no coherent energy policy exists in California.

The Committee described three comprehensive possible future

energy situations for the State. They concluded, however, that none

of the three courses of action could succeed because:

1) economic and technological uncertainties exist;

2) environmental uncertainties exist; and,

3) there is a general lack of concensus.

In their opinion all possible courses of action involved risk

except conservation which the Committee recommended should be pursued

to the maximum extent politically and economically feasible.

The legislation passed in 1974 established three tests which

energy conservation regulations must meet:

1) adverse environmental impacts are not permitted;

2) net energy savings must occur; and,

3) they must be cost effective.

Energy insulation standards for residential buildings were adopted in December, 1975. The standards for non-residential buildings were adopted by the Energy Commission on February 6, 1976, and were

344
due to go into effect on February 6, 1911 . The Construction Industry

Association challenged the latter in the Alameda County Superior

Court. The issue upon which the suit was brought dealt with the distinction between prescriptive and performance standards and a writ of

mandate enjoining enforcement was issued.

Thus, as of December, 1976, the county has not enforced

non-residential standards although they anticipated doing so early in

1977.

The circumstances in Sacramento County are the most complex of

the five counties studied. The county is currently implementing the

State's 1975 Residential Building Standards. The Energy Commission is

in the process of revising its 1975 Residential Building Standards.

The non-residential standards will go into effect as soon as legal

obstacles are overcome. In addition, the county has drafted its own Energy Conservation Standards for Residential Buildings, on which

three hearings have been held. Adoption of the county standards is

expected in early 1977. All persons interviewed were asked to respond

to questions in the context of regulations in place. Information

about proposed regulations and anticipated effects were recorded

separately.

Operational Effects :

Sacramento County's Building Inspection Division applied the 1975

State Residential Insulation Standards to 5490 single family units in

1976. The Associate Building Engineer in charge of the program

describes the State code as 99% prescriptive. The county used a simple, direct process to implement the code:

a) two sets of building plans are filed and logged by the

Building Inspection Division;

b) either a plan checker or building inspector reviews single

family dwellings plans for compliance with the energy

regulations

;

c) a commercial plan checker reviews plans for multi-family

structures

.

The time required by the plan check process is approximately two

minutes per set of single family building plans. The time required to

process plans is reduced because Sacramento County has several large

builders who use four or five basic models. Thus, familiarity with

the models diminishes the time required to process plans.

Field inspectors obtain a written certification from the

contractor which states:

a) the insulation is installed;

345
b) the thickness of the insulation; or,

c) the "R" value of the "blown-up" type if used.

The inspector also checks for double glazing if fenestration

exceeds 20% of the floor area.

There are virtually no work-load impacts arising from the

implementation of the State building standards for energy conservation

using these procedures.

The county responded to the question. Have the State insulation

regulations required the addition of any staff, training, space,

vehicles, supervision or other items? The answer was uniformly no. Fees have not been altered.

Political Effects :

Mr. Ted Sheedy, a Sacramento County Supervisor who also serves on

the County Energy Council, reports the State regulations have created

no additional burden on the county supervisors. The political

capacities of the county have not been affected.

Financial Effects :

Builders report that the "typical" three bedroom house has

increased in price from $40,000 in 1974 to $48,000 in 1976. The price

rise attributable to the State energy conservation regulation is

a) windows - zero;

b) air conditioning - zero;

c) heating - zero;

d) insulation - $200/house;

e) weather stripping - $50/house.

The fenestration limitations have had the effect of reducing

somewhat the amount of glass installed and a marketing impact is

expected but unknown. Concern exists because the California style

house normally contains considerable glass. The current energy

regulations have not caused delays in either the plan approval process

nor in the inspection process.

Thus, construction delays have not occurred and cost increases

are limited to insulation and weather stripping.

The loan quality of residential buildings has not been affected

according to the President of Guild Savings and Loan. No problems

have arisen from the implementation of the State energy regulations.

346
Legal Effects ;

The Assistant County Counsel for Codes provided a three-part

response to the question: What legal implications for the county has

the State-mandated energy regulations had?

a) Standards imposed by the State must be enforced or liability

could occur from non-compliance;

b) When a county legislature acts to adopt a standard based on reasonable data, no liability is incurred;

c) A County legislature is acting administratively when its

judgment is required in the application of a code, i.e., a performance code. It acts ministerially when applying a standard where no judgment is involved, i.e., a prescriptive

code. The greater legal exposure flows from the former

circumstance, however, a legislature is granted considerable

discretion.

Proposed Thermal Regulations for Sacramento County :

The State of California permits counties to adopt energy

regulations more stringent than the State Code. The proposed Energy

Conservation Standards for Residential Structures for Sacramento

County was prepared by the Living Systems consulting firm.

The goals of the proposed standards are:

a) Save about 50% of the energy needed for heating;

b) Add no capital cost; and,

c) Reduce operational cost.

However, the goals can be achieved by either a prescriptive or a performance method. The prescriptive method established minimum

requirements for: insulation (ceiling, walls, floors), roof color,

glazing area, glazing shading, and ventilation. The performance

method provides for component heat transfer calculations to

demonstrate that the standard is met. The performance concept is to

"design with climate," i.e., a climatological data base is established

and buildings are designed to maximize natural benefits such as solar

radiation in winter and cool summer breezes in summer.

Table III on the following page establishes the performance

required of residential structures. (Source: Energy Conservation

Standards for Residential Structures by Living Systems, Dec. 1976.)

347
TABLE III*

DETACHED GROUP I DWELLING UNIT

THERMAL STANDARDS

Floor Area Winter Heat Loss Summer Heat Gain

(sq. ft.) (BTUs/(sq.ft.)(days) (BTUs/(sq.ft.)(day)

500

1000

1500

2000

2500

3000

341

228

201

186

178

172

84

76

72

69

68

67

Note: Direct interpolation shall be used for floor areas not shown.

Infiltration and internal heat production are not considered

under the requirements of these standards. These are very

important considerations in the real performance of a building

and must be estimated when sizing heating and cooling devices

whether conventional or solar. However, for the present purpose

they are too variable to be standardized.

This proposal has been fully coordinated with the proposed 1977

revisions to the State Energy Code and is entirely consistent except

a) Roof color - County requires a light color.

b) Floor insulation - County proposed to require floor

insulation at 2800 degree days. The State proposes a cut-off at 3000 degree days.

c) Glass - County proposes to limit glass to 12%% of floor area whereas, the State proposal limits glass to 20% of floor

area

The reactions to the proposed standards are summarized below:

County Supervisor Sheedy - "The proposal is expected to be

controversial. The problems are expected to be worked out before the

Board of Supervisors receives the proposal for action."

Mr. Bill Streng, Builder and Mr. Jim Merry, Director of Building

Industry Association said:

"The energy situation does not warrant this kind of response. The

limitations of glass may affect the marketability and

pleasantness of homes. The permit approval process is expected

to require three (3) weeks based on their City of Davis'

for:

348
experience. (Davis has a similar code.) Construction plans will

have to be changed. Delays in the inspection process are not

anticipated based on the Davis experience."

"The County Administrative Staff and Builders design staff are

not now qualified to implement the proposed code. Substantial

training is expected. The time required to process the plans

will demand additional staff at substantial cost to the county

and the private design cost of the home will be increased. Costs

will be passed on to the home buyer."

The Associate Building Engineer, Mr. Gene Piatt confirmed that

more staff will be required to implement the proposed energy

conservation standards.

REFERENCES

The following were supplied by California Energy Resources

Conservation and Development Commission:

1) Draft Energy Policy Overview Report ; October 26, 1976

2) Electricity Forecasting and Planning Report ; September 24,

1976

3) Quarterly Fuel and Energy Sununary , Volume 1, No. 4, Fourth

Quarter 1975

4) Sub-Chapter 4: Energy Conservation, Article 1, Residential

Building Standards , December 23, 1975

5) Revised Report on Energy Conservation Standards for New

Residential Buildings , November 17, 1976

Sacramento County supplied Draft: Energy Conservation Standards

for Residential Structures ; by Living Systems, Dec. 1976.

MONTGOMERY COUNTY, MARYLAND

The previous studies have reported the impacts of State-mandated

energy conservation codes on counties. The context of the Montgomery

County report is different. This County developed its own code and is

in the process of adopting it. Consequently, there are no impacts

derived from implementation. The purpose of this section of the study

is to review the policy development process and examine its impact on

the final product. Since most of the counties in the country do not

come under a State building code, this kind of examination may have

high transferability value to them. Maryland does not have a statewide building code.

349

III
The State of Maryland has developed a model building code which

counties and cities may adopt under permissive State legislation. The

Model Performance Building Code as it is called is recommended by the

State and it now includes an energy efficiency chapter.

The Montgomery County Building Code is a Building Officials and

Code Administrators (BOCA) code modified to meet local needs. The

county proposes to add an energy section entitled: "DIVISION IV

THERMAL ENERGY CONSERVATION."

Montgomery County first considered an energy conservation code

for philosophical reasons. Two members of the County Council and the

County Executive believe in energy conservation and have publicly

supported conservation as a proper role for a county government.

Accordingly, the County Council resolved:

On July 1, 1975, the Montgomery County Council adopted Resolution

No. 8-311, recognizing an immediate need for developing energy

conservation standards in the construction of buildings and in

the use of heating, cooling, and lighting equipment. This

resolution established a Citizens' Advisory Committee on Energy

Conservation Standards in the County Building Code. The

Committee was charged with reviewing the current provisions of

the County building code and recommending areas in which

amendments are needed in order to enhance energy conservation in

the County. The Committee was officially appointed on December

9, 1975, and charged with producing an initial report by June 9,

1976.

The Committee was composed of nine prominent citizens many of

whom possess expertise in research and/or conservation.

The committee used ASHRAE 90-75 Energy Conservation in New

Building Design as a source document. Since ASHRAE 90-75 is a standard and not a code, the Committee relied on the "BOCA Preliminary

Code Revisions of Energy Conservation" for guidance in converting the

standard to code language.

The committee also established two tests which its recommended

code had to meet:

1) the recommendations must be practical, understandable and

capable of adoption; and,

2) they must be enforceable.

The committee decided it could use one or both of two approaches

to energy conservation in buildings. First, the transfer of heat

through building surfaces could be controlled by specifying maximum

permissable values for thermal transmittance . Second, air leakage

through cracks, seams, and other openings could be reduced. The

proposed changes address both issues. Both are achievable within the

standard practice of the construction trades in their opinion.

350
The proposed Montgomery Code is summarized below:

SUMMARY: MONTGOMERY COUNTY CODE (proposed)

Item Montgomery County Proposal

Scope all conditioned buildings

Design

Parameters

Alternative analysis

system permitted

Thermal transraittance

values

-ceilings

-walls

-floors

(slab-on-grade)

Fenestration

Condensation Control

Air infiltration

Heating/cooling system

70° winter

78° summer

yes

.05

.24 residential

varies w/const.

no limits; Uo value declines

as fenestration increases

none

ASTM-283 standard applies

minimum coefficient of

performance specified

The policy development process used in Montgomery County is not

all uncommon and is suomiarized below.

Policy Development Process:

a) County Council actions

1) declares need

2) appoints committee

3) gives committee its charge and a time line

b) Committee actions

1) defines the problem;

351
2) establishes the tests for its product, i.e., practical,

understandable, enforceable and capable of adoption.

3) collection and analysis of data

4) considers alternatives

5) reviews drafts

6) approves and recommends a report

c) County Council

1) receives report

2) calls hearings on recommendations

3) schedules action on report for June, 1977

The committee appointed was composed of prominent, capable people

with excellent skills in the field, including architects, builders,

and engineers.

They had the benefit of a large professional county staff

committed to the enterprise. They also took advantage of their

Washington location and drew on the professional skills of the

National Bureau of Standards, Building Officials and Code

Administrators, International Inc. (BOCA), Suburban Maryland,

Homebuilders , National Capital Heating and Air Conditioning

Association, NOJC, and Shefferman & Bigelson Company (a consulting

firm)

The conclusions of the committee were that an energy code was practical and:

1) The proposed code is recommended.

2) The proposals are energy conserving and cost-effective.

3) They are practical, understandable and enforceable.

In the judgment of the committee, the impacts of the recommended code

are

a) Homeowner effects

No dramatic changes in the construction of the home, but

some added material cost with a payback generally less than

four years is expected.

352
b) Commercial User effects:

1) Average annual reduction of 40% or more in energy

consumption.

2) Reduced construction cost in every case.

c) Construction Industry Effects:

1) Design approaches will have to be modified, especially

for commercial buildings.

2) More design effort required of builder because the

building must meet higher standards.

d) County Government effects:

1) An additional plans examiner will be required (a

mechanical engineer)

.

2) Cost will be $25-30, 000/yr.

3) One additional on-site inspection will be required and

the cost can be absorbed initially.

Inasmuch as the code has not been adopted, legal, financial, and

political impacts are not impossible to document, and therefore are not included in this County study. There are three important

principles to be derived from the Montgomery County experience.

a) The Council made three critical judgments at the outset by

declaring its values.

1) energy conservation is important.

2) there is a role for the County government to play.

3) the process used to define the substance of their role

would be democratic.

b) The County's approach to the committee was professional:

1) the change to the committee was clear.

2) the time line was explicit

c) The code development process was logical and professional:

1) problem definition

353
2) data gathering and analysis

3) available alternatives

4) debate

5) conclusions and recommendations

REFERENCES

1) Report of the Citizens Advisory Committee in Energy Conser- vation Standards in the County Building Code , Montgomery County,

Md. (June, 1977)

2) Energy Conservation Plan , Montgomery County (Oct. 1976)

3) "Memorandum on the Proposed Energy Conservation Amendments,"

Charles Rand, Assistant County Attorney (Dec. 24, 1976).

354
CONCLUSIONS

The thermal efficiency codes examined contained numerous similarities:

a) each is an amendment to an existing building code (except

California)

;

b) all require enforcement by local code officials;

c) all are both prescriptive and performance codes;

d) all are minimum codes except for Minnesota which is both a minimum and maximum code

;

e) the thermal transmittance values vary remarkably little

considering the wide difference in weather conditions;

f) the design standard is 70° for winter (68° for Minnesota),

The previous standard was 72°.

There are some differences among the codes:

a) Three limit their scope to residential buildings.

b) Only Minnesota applies the code to all buildings. The

Montgomery County proposal is intended to apply to all

buildings

.

c) Only Minnesota permits the county to require a building site

analysis which maximizes solar radiation. Sacramento County

proposes to add such an item.

d) Condensation control is not uniformly regulated, although

three states require a vapor barrier.

e) Three states have adopted a standard for air infiltration.

f) A workmanship standard is legislated in only two states.

The enforcement of an energy conservation code has produced many

similar results for counties:

a) Elected officials report no political impact from the

implementation of State-mandated thermal efficiency

standards. Some concern has been expressed about the

proposed revisions which may be controversial.

b) County Attorneys report neither legal action nor inquiries

arising from the implementation of thermal efficiency

standards. They all report that a failure to implement a State code would give the county its greatest legal

exposure - an unlikely event in their opinion.

355
c) Counties have implemented State-mandated thermal efficiency

codes on time and without major problems.

- no new personnel have been added as of December, 1976 - no reorganizations - no fee increases (one increase proposed

for 1977) - no capital outlay - minor additional cost

increases have been absorbed in current authorizations

d) No delays in the plan approval process have occurred as a result of the review for conformance to thermal efficiency

standards

e) The on-site inspection for required thermal efficiency items

has not caused construction delays in the opinion of county

officials. Most builders agree.

Counties report dissimilar financial impacts as illustrated by

the chart on the following page.

A caution about the use of this financial data is in order.

Local conditions have a direct impact on costs. For example, all of

the counties had increased workloads in 1976 compared to 1975. Yet,

four had experienced a decline in the amount of building activity

between 1972 - 1975. Thus, an ability to absorb added work existed in

these organizations during the period of this study (1976). Further,

the limit to which added work could be absorbed was reached in

Washington County in 1976. Sacramento County reports a need to

augment staff to accommodate changes proposed in the revised energy

code.

Three counties expect to add staff to the Building Inspection

Division in the future:

a) Sacramento County - Due to extraordinary growth and an estimated need if revised energy standards are adopted.

b) Washington County - One person has been added to the 1977

budget at a cost of $15,000.

c) Montgomery County - The proposed code includes the addition

of one mechanical engineer in part due to the energy code

and due to the current absence of such a position.

Estimated cost is $25,000 to $30,000.

Builders report increased cost for labor materials in order to

comply with the State codes . Cost experienced to-date ranges from

$100-400/unit.

Builders report that most of the costs are experienced by the

"budget" builder. Those who are building homes in the $40,000 and

above range say their practice exceeded the standards and no cost

increase has been experienced. The single exception is Montgomery

356
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357
County where a builder believes manufactured windows will cost

$400-500/unit and higher design fees will be necessary to comply with

the proposed codes.

All builders report the codes are cost-effective within five

years. Two builders (NC and MD) based the judgment on a professional

cost-benefit analysis. The others rely on their experience and

judgment

Finally, the situation in each State is dynamic. Several are considering modifications in their codes which, if adopted, will

affect the implementation process and its effects on counties. This

investigation concludes that counties having a building code and an experienced staff can accomodate an energy code which establishes

certain standard practices as a minimum.

As the complexity of the code increases and as the degree of

change from common practice is required of builders, the time and

effort on the part of the county will increase. Each of the major

categories of analysis —legal, political, financial, and

operational--will be impacted to varying degrees.

358
REGULATORY ADMINISTRATION: A FUNCTION OF

PERCEIVED PRIORITIES, COSTS AND BENEFITS

by

Norton S. Remmer, P.E.

Commissioner,

Department of Code Inspection

City of Worcester, Massachusetts

This paper discusses the problems of building regulatory agencies

in facing rapid advances in the technology and scope of building

regulation and the implied increase in volume of work. The paper

attempts to identify distinct classes of obligation for the regulatory

agency based on a range of requirements starting with those proven

critical to life safety and those mandated by legislation and highly

visible to the public to those which represent the possibility of

applying wide discretion in judging risk and assigning a priority

based on community benefits. The paper gives examples of how

decisions affecting risks versus benefit might be implicitly applied

in every day operations of an agency and the significance of these

judgments in terms of an acceptable risk level. As workloads increase

and technology and mandatory legislation increase in scope and volume,

local regulatory agencies, faced with limited resources, must make

decisions which reflect a systematic prioritization of functions based

on judgments of risk, costs, and benefits.

Key Words: Building codes; cost-benefit; decision making; priorities

regulatory agency: resources; risk.

359
INTRODUCTION

Building regulatory agencies are faced with rapid advance in the

technology of regulation of buildings. In addition, there are also

rapid increases in the number and character of Federal, State, and

local constraints and mandates imposed on the regulatory process. As

technology advances and the scope for doing either good or harm seems

to expand, government at all levels becomes activated in response to

observed dangers and risks, or in anticipation of future benefits.

One of the results of this burgeoning technology and awareness is

the recognition that regulatory agencies, limited in both staff and

expertise, must make decisions, either explicitly or tacitly, on allocation of its limited resources. This paper attempts to look at

this allocation of resources according to different levels of

constraint based on legal mandates, observable compliance, and the use

of discretion in assessing risk and benefit to the community as a whole

DEMANDS OF NEW TECHNOLOGY

Recently we have seen an unprecedented number of events and

reactions at all levels of the regulatory process. Model code groups

have made many significant changes in their codes to reflect the

increased sophistication of understanding of building code problems.

The code groups have also reacted to technology fostered crises, and

improvements, with many code changes.

The development of the high-rise and its proliferation in great

numbers led to a higher statistical probability of observing faults in

the regulation of high-rise structures. The reaction to the danger,

proven by several disastrous high-rise fires, was to immediately

create a multitude of specialized requirements for the design of such

structures and the equipment in them. In many cases, the regulations,

in either identical, similar, or differing forms were promulgated

concurrently by agencies at State and local levels.

The ubiquitous intrusion of plastics into virtually everything

has created an even more critical problem for all types of buildings,

and therefore, regulatory agencies. However, this technology expands

and changes so quickly that it is difficult to determine what the

risks are before a new field of use has been developed and has created

a different scope of risks. Once again, as the observation of the

problem generated a realization of the risks, reactions were generated

across a broad band of levels, from Federally imposed restrictions, to

standard-making bodies, to local authorities and fire departments. In

conjunction with the new technology of evaluating the risks of

plastics used in different construction circumstances, a new set of

regulations for controlling their use has been developed and is

continuing to be developed.

The threat of earthquakes and the problems of establishing the

risk and doing something about it in both new buildings and existing

360
buildings has been emphasized by recent events in other countries.

In response to a recognized threat in Massachusetts, the State

promulgated a uniform mandatory set of new regulations far more comprehensive than were previously in effect anywhere in the State.

Finally, we can refer to an entirely new and extensive set of

regulations controlling energy conservation. A review of the status

of energy conservation regulations reflects the fact that regulations

are being imposed at many levels; local, State, model code, and in

national standards.

The general tendency appears to be that we are adding

regulations, codes, statutes, laws, and standards to the building

regulatory system at a rate that is greater than that at which any

material is being deleted. In fact, I would guess that the rate of

adding material is an increasing rate. In addition to adding

material, the material represents a technology which is relatively

complex compared to the rest of the regulatory technology; involves

many new standards and extensive demands on allocation of agency

resources

.

Among the four examples of recent developments in code technology

cited above, there are some interesting points to be observed. The

response of codes to the problems of high-rise construction was in answer to a serious life safety hazard. Previous technology had

accepted basic concepts of code provisions as acceptable to provide

adequate life safety in high-rise structures. However, the result of

disasters which occurred showed that previous concepts erred greatly

both in gross requirements and equally in details such as recognizing

the problems of vertical chases and penetrations, and the need for

complex systems of communications and mechanical equipment control.

The plastics problem represents a serious life-safety threat

across all the range of uses in all buildings where it occurs. It has

rapidly replaced conventional materials, which historically have not

been a serious hazard, or which through experience, have been

controlled in use, and created potential new hazards in both gross

application and in details. While it is now possible to deal with

some of these hazards effectively, an entire new technology is

required to bring the use of the material within a range of hazard

which is more understandable to regulatory agencies.

The earthquake problem represents a uncompromising evaluation of

risk, primarily life-safety, versus benefits. The risk involves an evaluation of likely return period for a specified level of events.

As a broad generalization, it can be said that for the same level

event, as the return period increases in length, the design

requirements tend to be diluted. And, in general, they are diluted in

terms of the detail required to be enforced. This is an implicit

reflection of perceived risk and benefit. There is no perceivable

benefit to addressing in detail events, even one likely to be

catastrophic, which are predicted to occur several thousand years

apart.

361
Finally, if we look at energy conservation in terras of

traditional code tenets, we must come to the conclusion that we are addressing an unabashedly new area of code enforcement - enforcement

of national policy. It is clearly not related to life safety or health and only vaguely related to general welfare.

In addressing these four issues, four clearly differentiated

aspects of the administration of the regulatory function emerge. In

the high-rise we see a high risk, a highly visible and identifiable

structure demanding a high concentration of effort and attention to

detailed systems, and to quality control. In plastics we see a unique

material with a multitude of hazards and uses associated with it

demanding careful attention to use under any circumstances, careful

identification of its existence and follow through in its control in

all buildings. In the regulations for seismic design a wide spectrum

of requirements are available which can be justified based on a perceived risk/benefit determination. Based on this determination,

the amount of detail in administration of the regulations can also be

established over a wide range. And finally, in energy conservation,

we are faced with what, in code terms, can only be described as a mandated legal obligation, having little to do directly with life

safety or health.

OBVIOUSLY MANDATORY REQUIREMENTS

There are obligations in regulatory administration which may be

termed obviously mandatory. Generally, these are items whose

enforcement represents major considerations of life safety and are easily observed or are established by specific statutory requirements.

An example might be the awareness that wood frame construction is very

limited in height allowances, and a five story wood frame building

would bring instant recognition of major code violation. In many

jurisdictions, high rises require sprinkler systems and there is a general recognition of this requirement. The lack of compliance

becomes instantly observable and the danger to the public is as well

understood by the public as by the regulatory agency and the design

professional. As a third example we might consider the requirements

for egresses. The availability of at least two adequate egresses in

most places of assembly can be easily recognized even by the public as critical to their safety.

In addressing these requirements, there is a compelling necessity

for compliance for four basic reasons: 1) They have been proven

critical to life safety, 2) they are highly visible, 3) there is a general awareness of the requirement in the general public, 4) they

are mandated either by law or by very specific, uncompromising

regulations

REQUIREMENTS WHICH ARE NOT OBVIOUS

In the administration of the codes , there are many areas where

the result of enforcement would not be obvious to observers, users.

362
builders, or even regulators. In the normal course of construction

many elements regulated by code are covered and hidden from view and

only sampling techniques of enforcement can be used to try to ensure

compliance. Some examples are the placement of reinforcement in

reinforced concrete structures and in reinforced masonry construction;

the use of properly graded lumber wherever required; and the

placement, quality, density, and thickness of sprayed-on f ireproofing.

In many of the examples cited, variations from the code or even non-compliance would only be apparent under extreme conditions of use. Conditions which would represent an extremely low probability of occurrence. In the case of placement of reinforcing steel and the use

of graded lumber, we are most likely concerned only with structural

load-bearing capacity. In the case of firestopping and f ireproofing,

we may only be dealing with exposure to a significant fire. For all

of these requirements, there is some decision required about the

extent of commitment of time and resources to quality control before

the items are hidden from view.

REQUIREMENTS WHICH ARE PRIMARILY BASED ON ADMINISTRATIVE POLICY

Finally, there is a considerable portion of the regulatory

agency's work which is adaptable to enforcement criteria established

by local policy decisions. Most code administrative sections provide

great latitude for local discretion in both the detail and the vigor

with which much of the code is enforced. This is especially true with

respect to existing buildings subject to alterations and change of

use. Certainly the typical sections of codes which establish the

extent of code compliance based on cost of repairs related in

percentage to value of buildings provides both the building official

and the municipality with broad range of cost/benefit options based on locally perceived risks. Even simple standard requirements in codes

relating to required egress lighting levels and ventilation

requirements can be administered in accordance with a degree of

accuracy which, while always subject to measurement, may only create

an awareness by its existence or absence. Surely measuring light

levels at all locations and cubic feet per minute of ventilation

required to a close tolerance could create a significant burden on both a building department and a builder.

Finally, it seems probable that energy conservation requirements

may represent a single area which has characteristics most adaptable

to discretionary decision-making and prioritization in terms of

perceived costs and benefits. Virtually none of the requirements are fundamental to life safety, and they might only be related to health

and welfare by a tenuous bridge of economic necessity - presumably

outside of the normal context of code application. The allocation of

departmental resources to deal with the extensive additional detail of

energy regulations represents a significant burden which has to be

thrown into the entire pot of legal obligations, risks, and benefits.

363
RISK AND ITS INFLUENCE ON BENEFIT-COST

Chauncey Starr^''^'^ in discussing the question "How safe is safe

enough?" discusses several interesting points related to involuntary

risk taking in what he calls our "sociotechnical" systems. He comes

to the conclusion that the rate of death from disease is an upper

guide in determining the acceptability of risk - somewhat less than 1 in 100 years.

He also states that natural disasters ("acts of God") tend to set

a base guide for risk - somewhat more than 1 in a million years and

that man-made risks at this level can be considered almost negligible

and may be neglected if they are several magnitudes less. He

concludes that there is a risk trade-off range of one million for

societal policy related to acceptability of public risks associated

with sociotechnical systems. This translates basically into a risk of

from one fatal accident in one hundred years, to one in a million

years

This implies that even some arbitrary decision making by the

regulatory agency to accommodate what may be called community benefits

may represent a very safe risk within this total range of apparently

acceptable risks.

As a simple example of some of the possibilities involved in

benefit risk decision making, let us consider a multifamily

residential building. For the sake of example only, consider the

requirements of the BOCA code (an identical example could be made with

any of the model codes) for a type 3B construction, R-2 multifamily

residential use building. The basic code area limitation is 13,200

square feet. This basic fire area represents a code measurement for a certain hazard criterion. It must be presumed that variation from

this value establishes a new hazard, or risk. To be allowed to exceed

this area even by a small amount, there is required a significant

construction penalty. It is assumed that the only remedies available I are fire walls or sprinklers. While we are not sure what the original | risk involved was, it is evident that by marginally increasing the \ area a stiff price must be paid and we must surely reduce the risk by | several orders of magnitude by the addition of a fire wall or | sprinklers. If marginal variations in area are ignored and allowed, ! there is a tremendous savings in cost and a probability that the risk

is still within a perfectly acceptable range.

In the same building, the following fire ratings for elements are | applicable:

1 hour

I 2 hours

I 1 hour

1 hour

I

1. Interior bearing walls and partitions

2. Fire enclosure of exitways

3. Exitway access corridors and vertical

separation of tenant space

4. Floor construction including beams

364
If these elements are constructed of sheetrock and wood studs,

the assemblies necessary to achieve the fire-ratings are specified in

great detail in an appropriate catalog of fire rated assemblies. To ensure compliance with the code would require extensive commitment of

time for quality control in the form of inspection. It is rarely

possible to allocate more than enough time to spot check. And spot

checking implies the possibility of variations from standards and a possible change or risk based on required fire ratings. In fact, the

extent to which inspections of such assemblies are carried out and the

degree of detail checking is a discretionary decision of the

regulatory agency based on its available resources and the particular

importance attached to the control of such assemblies by the

particular regulatory agency.

A particularly interesting and direct application of recognizing

a level of risk and its effect on cost-benefits occurred in the City

of Long Beach, California. The City of Long Beach contracted with the

J. H. Wiggins Company to recommend new earthquake provisions for the

city. Two of the risks itemized by John Wiggins (2) were as follows:

1. "Developed new code criteria based on equating involuntary

earthquake risk with other voluntary risk situations such as auto accidents. This introduces the new concept of Balanced

Risk design."

2. "Provided a means by which representatives of lay citizenry

can establish or modify code limits recommended. Several

strengthening tables were prepared that related to the

death-risk expectancy."

365
CONCLUSION

There are many levels of application of building regulatory

requirements. At some level of application there is either an explicit

or a tacit application of priorities in terms of perceived costs and

benefits. While the priorities generally are related to risks,

whether understood in terms of risk/hazard or not, the influence of

availability of resources and their application and political and

social pressures alter the priorities and the consequent cost benefit

arrangement.

(3) Lester B. Lave in his paper on "Risk, Safety, and the Role of

Government" says:

"Similarly, increasing the safety of an automobile increases its

price and denies the product to the poor. Denying a man his livlihood

and mobility in order to increase his safety by one change in a hundred thousand hardly seems optimal."

And further:

"However, as increasingly higher safety standards are imposed at

increasingly higher prices, more and more people, particularly the

poor, will be hurt by being priced out of the market."

And finally:

"To set safety standards well, one must determine the cost of

satisfying the standards and the benefit to society from the added

safety. This is very difficult to do properly."

All three of the previous statements by Mr. Lave could be applied

equally well to building construction and especially housing.

As the technology, scope, and demands of the regulatory process

expand, the more expensive and demanding it becomes for municipalities

to fulfill their obligations. With limited resources available, it

becomes a matter of necessity for local governments to fulfill their

obligations based on a perception of those requirements which are relatively absolute in nature and those which can be established on

the basis of priorities reflecting apparent acceptable risk balanced

against community benefits.

366
REFERENCES

1. Starr, Chauncey, "Benefit - Cost Studies in Sociotechnical

Systems," Perspectives on Benefit - Risk Decision Making , National Academy of Engineering, Washington, D.C., 1972.

2. Wiggins, John H. , Jr., "Earthquake Safety in the City of Long

Beach Based on the Concept of Balanced Risk," Perspectives on Benefit - Risk Decision Making , National Academy of Engineering,

Washington, D.C., 1972.

3. Lave, Lester B. , "Risk, Safety, and the Role of the Government,"

Perspectives on Benefit - Risk Decision Making , National Academy

of Engineering, Washington, D. C. , 1972.

367

DEVELOPMENT OF INTERFACE BETWEEN THE REGULATOR

AND THE MANUFACTURER'S QUALITY CONTROL PERSONNEL

by

Ed Starostovic, P.E.

Executive Vice President

Product Fabrication Service

Madison, Wisconsin

The subject of this paper encompasses the manufacturer's commitment to

quality control including designation of inspectors who are held

accountable. Other aspects will include coverage of:

o Development of inspection aids

o Regular monitoring of both product and inspection personnel

o Training of personnel in a formal classroom environment

including required annual recertification

o Classroom written examination, grading process, and PFS

Quality Assurance Council review

o Progress reports after classroom training and as a prerequisite for final written certification

o Maintenance of year-to-year certification

o Decertification procedures

o Case histories of decertification

o Impact on product quality

Key Words: Certification; compliance assurance programs;

industrialized building construction; inspection;

personnel qualifications; quality control manual;

regulations; Third party agencies; training.

369
It has been my privilege to be involved in compliance assurance programs for industrialized constuction for over 20 years, and I am convinced that any program which is not centered in an effective

hour-by-hour policing by the manufacturer of his own production in his own behalf will have serious flaws no matter who is coming in from the

outside to inspect or how often he is coming. In recognition of this,

it was fifteen years ago that Product Fabrication Service, the third

party independent inspection and testing agency I now head, made this

an integral part of their program. We require that the manufacturer

have a sound quality control program before we will certify quality

based on our audit inspections. However, in recognition of the fact

that very few manufacturers have such programs or have expertise and

trained manpower to set up a program on their own, the PFS staff will assume a major part of the chore. This involves the preparation of a quality control manual which establishes procedures, quotas, tests,

record keeping, including forms, certificates and labels, and it

involves the training and subsequent examination and certification

of in-plant quality control personnel . Then there is a continuing

surveillance and supervision of the Certified PFS Inspectors by the

PFS Staff Audit Inspectors who are in the plant on a regular basis.

We think this is one of the most important services that PFS provides.

Most of the regulatory bodies which have established requirements

and approval procedures for industrialized housing have adopted this

concept and require that the manufacturer submit, in addition to plans

and specifications, a plant procedural manual which sets forth in

detail an in-plant quality control system which is audited on a frequent and continuing basis by an approved third party agency.

Organizationally, the manufacturer's quality control personnel

should answer to management above the level of the Production Manager.

Lines of authority should never place the inspector in the position of

passing judgment on work for which his boss is directly responsible.

His organization chart should clearly show that quality control

personnel are not subject to this kind of pressure. On the other

hand, quality control can make a substantial contribution to solving

production problems in an atmosphere where each group realizes the

value of each other and works together in turning out production in

which the entire company can take pride.

As far as quality control personnel qualifications are concerned,

if they are working with an agency which has a training program and

assists in setting up their quality control system, they do not need

to have people with previous quality control experience -- neither do

they have to possess craftsman ability in the trade whose work they

inspect. A particular academic background is also not required. PFS

ad\ ises the manufacturer to look for a man who has a broad background

in construction -- he should have had supervisory experience at least

at the leadman level of responsibility -- and this should have been in an industrialized housing situation. He should have reasonably good

judgment, be able to get along well with fellow workers, and should be

able to make decisions with resolve. He should be able to say "no"

with both tact and firmness.

370
Some background in building codes would be helpful, but is not

necessary with agency training. General code interpretation is not

involved since the inspector is always working with very detailed

plans and specifications which have previously been evaluated by the

appropriate authority.

The manufacturer's quality control system should begin with an acceptance procedure for raw materials as received at the plant. It

will involve a spot check on an established quota basis of the work as it is accomplished at the various work stations throughout the plant.

It should include a check of all plumbing, electrical, mechanical, and

structural systems after the work is complete but before it is covered

up by subsequent work. It will include the procedures by which

non-compliance at any point can be brought to the attention of

production so that it can be repaired or replaced before the unit

reaches the end of the line. The in-plant quality control will want

to include not only those things about which the regulatory body is

concerned, but also checks of those things that are important in their

relations with their customer in seeing that he gets the colors and

patterns specified, scratch-free finishes, etc. They will want good

records of all inspections so that regulatory bodies can be satisfied

and so that they will have accurate information if complaints are subsequently received.

The Quality Control Manual is prepared by the manufacturer's

inspection personnel usually. It includes the inspection aids the

Certified PFS Inspector will need to implement and maintain an effective quality control program at his plant. These aids include

inspection check lists, testing equipment, and the plans and

specifications

.

The in-plant inspector must know how to use the test equipment

and check for its calibration. He must know how to read plans and

specifications correctly and to know enough about the material

specifications to be able to refer to his codes and standards library

when references are made in the specs, such as "plywood shall meet

PS-1-74."

This in-plant inspector truly must be a very knowledgeable

person. Yet, throughout the industry today little is done by

management to assure his competence. Many manufacturers, indeed, rely

entirely upon production supervision and monitoring by the inspection

agency for compliance; however, it is a condition of every PFS

contract that the manufacturer must have a comprehensive quality

control department including in-plant inspectors certified by PFS.

The Certified PFS Inspector must meet rigid closely monitored

performance criteria to obtain and remain certified. Not only are there initial qualification requirements, but once certified, the

inspector must continue to maintain his expertise or he will loose his

certification. He must attend one additional seminar annually to

remain eligible for recertification.

371
Once chosen as a trainee by management and accepted by PFS, he

must attend the next regularly scheduled PFS Training Seminar. The

Training Seminars are organized by PFS Staff twice annually and held

in either Madison, Wisconsin or some prominent eastern city. They run

for two days during which time the trainee receives special

instructions in a classroom-like atmosphere. These instructions cover such things as: lumber and plywood grading, electrical and plumbing

codes, professional quality control techniques, latest code changes,

heating and ventilation, including an emphasis on condensation, record

keeping, product liability, energy, adhesives and mechanical

fasteners, and fire safety. (Refer to Tables 1 and 2)

At the end of the second day, each inspector must take a written

examination. Recently, part of their examination has included a practical exam where inspectors visit a mobile or modular plant and

actually conduct an inspection of products on the assembly line.

In these cases, PFS Staff prepares the product on the line with

deliberate violations of the regulations covering subjects which have

specifically been discussed during the classroom training.

The examination is graded using statistical methods. Grades are distributed into a "normal" or bell curve, and grades below the first

standard deviation of the mean are considered failing. This results

in a minimum passing grade which varies with each exam depending upon

the grade distribution. However, this process is necessary because

the instructors are each asked to submit five questions for the exam based upon what their subject will cover. This process assures that

the instructors will cover the exam questions and that the exam questions are always different for each exam.

Once the grades are compiled, they are submitted with my

recommendations to the PFS Quality Assurance Council Chairman for his

review. If agreed, each attendee is advised that he either passed or failed the exam. He is not certified at this time. He is certified

by the Quality Assurance Council only after a satisfactory

progress report is received from the PFS Quality Assurance Inspector

supervising him and his plant. The progress report includes an evaluation by the PFS Inspector of the trainee's record keeping,

knowledge of his job and time on inspection. (Refer to Figure 1).

After the trainee passes the exam and receives a recommendation

for certification by the Staff Inspector, the trainee receives a signed certificate. (Refer to Figure 2).

This certificate includes the signature of the Quality Assurance

Council Chairman and the Executive Vice President of PFS. Worth

noting the certificate expires after one year automatically.

Every Certified Inspector must attend at least one PFS Seminar

annually to retain his certification. Regular Certified Inspectors

are usually backed up by a second man, sometimes from Engineering, to cover him in case of illness or vacation. These back-up men are required to perform one complete inspection per month minimum to

remain certified.

372
Monitoring of the performance of the Certified Inspector protects

the integrity of the program. Even in states or under the HUD Mobile

Home Program where each unit must be seen by a PFS Staff Inspector,

the manufacturer must still have a Certified Inspector in his employ.

Monitoring includes not only a check of the product on the assembly

line, but a check of the inspection records and test equipment used by

the Certified Inspector. Any glaring and obvious inconsistency

between the inspection records and the product on the line is a tip-off that the in-plant inspector is not doing his job.

You have probably noticed my reference to a PFS Quality Assurance

Council and are wondering what or who they are. The QAC consists of

six members of the public who serve without compensation. QAC members

are invited by Council action to participate as Members of the

Council

.

Qualifications include being well known and of good reputation in

the building industry. Several members of the Council must represent

local building officials; others include professionals and consumers.

No members of the Council may in any way be associated with the

building industry. The present Chairman of the Council is Bernard E. Cabelus , Building Official, State of Connecticut. The immediate Past

Chairman is Charles Hagberg and his predecessor was Harry Stone.

The function of the QAC is to monitor the training and

educational programs of PFS and to assure that only qualified staff

meeting minimum qualification requirements are employed.

Getting back to the certified inspectors, a log is kept on the

performance of each inspector including various exam grades and

changes of employment. The inspector can remain certified even

though he changes jobs provided his job duties remain substantially

the same. Hence, the Certified Inspector Training Program is truly an educational program of particular value to the inspector himself.

This value helps assure that he will do his best to do a proper job.

It is not difficult to be decertified ! To date, the PFS Quality

Assurance Council has decertified two individuals and reprimanded a third.

CASE HISTORY A

A small firm insisted upon the production superintendent being

the back-up Certified Inspector. This man personally was a strong

supporter of the Certified Inspector Program and assisted actively in

implementing the in-plant quality control program.

He voluntarily commented after attending his first seminar that

for once he finally understood what the grademark meant on lumber.

This man is about fifty-five years old and has been involved in the

building trades most of his working life. He knew building

construction, but had a tough time learning about code enforcement.

373
At his second seminar, required to maintain his certification, he

failed the written exam by two percent. He was decertified. Today he

is no longer employed by the manufacturer, but the manufacturer is

still a PFS client in good standing.

CASE HISTORY B

A mobile home producer in the midwest used the company engineer

to also do in-plant inspection and apply HUD labels between visits by

a PFS staff inspector. This manufacturer and his engineer were not

particularly enthusiastic supporters of the program. After numerous

attempts by the staff inspector to get cooperation, he went back

immediately the next day following a routine inspection to check on

several red tagged items.

He found them covered, the units labeled and about to be shipped

out. In addition to other actions taken to correct the mobile homes

in violation, he filed a written report concerning the actions, or lack thereof, of the certified inspector.

In this case, the certified inspector was immediately decertified

by me subject to confirmation by the Qaulity Assurance Council.

Confirmation came at the next regular QAC Meeting.

This incident occurred about three months ago. The manufacturer

is now looking around for a new DAPIA/IPIA.

CASE HISTORY C

During monitoring, it was found that a change was made in a house

which was not covered by a design approval.

PFS does permit certain minor plan or design changes which are judged to not affect the house safetywise.

The change affected the house structurally and should not have

been authorized without PFS office approval.

The Certified Inspector admitted that he made an error in

judgment in approving the change but said he thought the change was minor

In this case, the president of the company responded to our inquiry by hiring a new Quality Control Manager over the Certified

Inspectors. He did this after conducting his own investigation into

the reasons for the foul up.

Because the Certified Inspector did not willfully violate Code

regulations , it was decided by the PFS QAC to merely give him a written reprimand advising him that the reprimand would remain part of

his file at PFS for one full year. After one year of satisfactory

performance, the letter will be destroyed.

374
CONCLUSION

For the manufacturer, the Certified PFS Inspector Program does

involve a substantial investment in both time and money.

Yet at this time very little official recognition exists for the

program. Few states hold the Certified Inspector accountable in any

way. Likewise, HUD has not chosen to recognize the program officially

in any way. Considering this, it is extraordinary that PFS enjoys

virtually 100% support for the program from industry. We know that

some of our clients have joined PFS substantially because of the

training program.

Our experience shows that many inspectors are lost due to

promotions up into the organization. In fact, management often uses our training program for people they have their eyes on for management

positions later.

That the program is successful is obvious. We only hope that

you as the final authorities will work with PFS to develop the

usefulness of this program even further.

375
Table 1

LIST OF SUBJECTS TAUGHT AT PFS

TRAINING SEMINARS

Since Beginning (September, 1973)

SUBJECT HOURS

Introduction to Equipment 2

Records - Control 6

Quality Control 11

Relationship Bewteeen CI & Authority Having Jurisdiction 2

Codes and Standards 4

Lumber Grading Rules 6

Equipment Calibration 1 Inspection to U.B. Code 2

ANSI A119.1 Standard 6

In Plant Test to ANSI 119.1 2

Plumbing 20

Plywood Grading Rules 7 NEC 14

Heating, Ventilation & R. Valves 11

Fundamentals of Attic Ventilation 6

In-Plant Inspections 1 Agency Grademark on Lumber 7 PFS Program 5

Fire Safety and Protection 4

Adhesives 6

Mechanical Fastenings 2

Design of Mobile Homes Travel Frames 1 All-Plywood Beams - Mobile Homes 1 Mobile Homes Safety 1 Structural Analysis 4

Plan Review 1 Product Liability 2

HUD Standard for Mobile Homes 9

TOTAL 144 Hours

376
Table 2

SEMINAR ATTENDANCE SUMMARY

SEPTEMBER, 1973 THROUGH APRIL, 1976

There were 9 seminars with a total attendance of 136 men:

96 of these men were certified at one time 71%

82 of them are still certified 60%

14 of them are no longer certified 10%

40 of them were never certified 29%

1 of them was decertified because of exam failure

1 of them was decertified until he complies

Number of men who attended one seminar 85 63%

Number of men who attended two seminars 31 23%

Number of men who attended three seminars 14 10%

Number of men who attended four seminars 5 4%

Number of men who attended six seminars 1 1%

377
Figure 1

Confidential

PROGRESS REPORT

INSPECTOR TRAINEE

Date of Report:

Audit Inspector's name:

Trainee's name:

Manufacturer's name;

Plant:

This is the ( ) first, ( ) second, ( ) third report on this trainee.

Length of time under your supervision:

Evaluations

Record Keeping: ( ) acceptable ( ) unacceptable

Time on Inspection: ( ) acceptable ( ) unacceptable

Knowledge of his job: ( ) acceptable ( ) unacceptable

Other: ( ) acceptable ( ) unacceptable

Remarks

I ( ) do ( ) do not recommend this trainee be Certified as a

PFS Inspector.

Audit Inspector

Signature:

(This report will not be shown to the manufacturer or trainee

without prior clearance of the audit inspector)

PFS FORM #25 4/74

378
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i
LEGAL ASPECTS OF THE BUILDING REGULATORY PROCESS

by

Paul J. Moriarty, Counsel

Massachusetts State Building Code Commission

Boston, Massachusetts

Building regulations had a beginning, a middle and will have no

end. Since the time man first built a shelter which in some way

affected the shelter of another, building and housing regulations out

of necessity arose. As man progressed and his needs improved, laws were enacted to control his activities and a few of these laws

regulated the use and construction of his shelter. It will be

attempted here to briefly illustrate the ways in which this shelter

has been regulated and misregulated and to show that in several years

we have not yet reached an atomic age in the building regulatory

process. As the building regulatory process becomes more complex and

technical, the building official must become more knowledgeable and

technical. It will also be seen how the courts have reminded the

building official that the public need not tolerate a building code

requirement simply because it is so written.

Key Words: Building official; building regulations; code

enforcement; construction; court decisions; disasters;

economics; legal approach; regulatory process;

violations.

381
POLITICAL IRRATIONAL APPROACH

In the Year 27, a wooden amphitheatre near Rome collapsed and

killed or injured some 50,000 people and shortly thereafter we had the

beginnings of a politically oriented building regulatory system. As a result of a house fire in Boston in 1630 which spread to another

house, it was decreed by the elected officials that chimneys could not

be built of wood, and houses could not be covered with thatch.

Because of sickness in Boston in 1652, it was required that there be

at least twelve (12) feet between a privy and the street. It

immediately became necessary to have all passenger ships inspected

before leaving the docks due to the tragic capsizing at its pier of

the passenger ship General Slocum in 1904 in which over 1,000 people

lost their lives. In 1903, 600 persons lost their lives in the

Iroquois Theatre fire in Chicago resulting in sweeping changes in the

laws affecting theaters, not only in Chicago but by almost every state

in the union. In 1938 the Massachusetts legislature enacted the so called Boston Building Code subject to ratification by the City of

Boston's City Council. The City of Boston suffered through its

obsolete building code until the fateful evening of November 28, 1942

when a Boston night club, the Cocoanut Grove, overcrowded with

football festive people, found themselves in the midst of a small fire

which quickly got out of control and panicked over a thousand patrons.

Nearly five hundred (500) people lost their lives almost

instantaneously and another five hundred (500) received varying

degrees of burns.

On February 15, 1943, Boston's City Council referred to committee

the building code passed by the legislature in 1938 an on May 10,

1943, less than six (6) months from the fire that touched in some way

every Boston resident, and five (5) years from legislative passage,

the Boston Building Code became effective for the City of Boston. It was felt by those rational technicians, at the time, that this code

could not have prevented the fire nor the loss of life resulting

therefrom, but no one can argue that a modern building code was implemented out of the ashes of this holocaust.

These are but a few of the many thousands of cases which a tragic

incident had to occur before a public outcry resulted in safety

requirements being implemented by those charged with enacting laws. I dare say that although the cited cases range from the year 27 to 1943,

the more classic cases not mentioned occurred prior to the year 27 and

go beyond 1943. This political method of enacting codes by reacting

to a holocaust achieves an end result that is far from an acceptable

method of public safety protection.

AN ECONOMIC APPROACH

A tragic happening is often followed by an overaction by those

charged with enacting building regulations. These regulators totally

disregard the economic problems that they have created. This

irrational approach in building codes sometimes is later tempered by

code technicians who consider the feasibility of enforcing such

382
requirements by analyzing its cause and effect. In the simplist terms

they wonder why the regulators designed a short fused bomb to kill a few household insects instead of improving on the fly swatter.

In 1974, the Massachusetts legislature overwhelmingly enacted a law requiring sprinklers be installed in all new buildings over seventy (70) feet in height and an automatic fire warning system

installed in all new buildings not exceeding seventy (70) feet in

height occupied for residential purposes. In spite of a 1972 law

establishing a State Building Code Commission charged with adopting a mandatory state wide code to be effective on January 1, 1975, the

legislature charged the local fire officials with the interpretation

and enforcement of these two (2) laws over the objection of the

industry, the governor, and the building code commission. During

1975, it was found that the 351 local fire officials enforced these

laws in the manner fearfully expressed by the opponents. Many of the

fire officials lacked the technical expertise to draft guidelines for

sufficient, but not absurd, requirements. Thus we had requirements in

several communities for heat and/or smoke detectors in every

compartment, (closets, cabinets, attics, cellars and rooms), on the

theory that "two is better than one and three affords much more protection than two, etc." Several communities required any

residential building with over two (2) units to have their system tied

directly into the fire station, stating that they had no loss of life

since instituting these requirements, however, their statistics could

not determine if one detector in each unit, not connected to the

department, would also have saved these same lives. Would not

statistics also have shown that an early warning system is to alert

the occupants in order for them to evacuate before it is too late

since seldom will the fire department be at the scene before all able

bodied persons have evacuated due to this early warning. The

legislature in mid 1975 then heard a cry for help from its

constituents and the sophisticated fire officials, for a modified law

which would be uniformly enforced interpreted and thus less costly.

Heeding the cry, the law was amended so that the requirement and

interpretation was left to the State Building Code Commission who

enlisted the aid of a Fire Protection - Fire Prevention Board composed

entirely of fire specialists (11) such as fire department personnel,

fire engineers, and fire signal persons. With the aid of this board,

a fire prevention - fire protection section of the building code was adopted giving the Commonwealth perhaps the best regulations in the

country for such things as an early fire warning system and effective

fire suppression system.

As a code oriented group, generally only the building officials

seem to recognize that presently no one can prevent the loss of life,

health, and property losses caused by God (flood, lightening, etc.)

and intentionally man caused catas trophies (bombs, arson, etc.). With

modern technology today, it may be possible to nearly eliminate our personal losses but is the public ready to accept the cost of such

protection both financial and aesthetic? Would the public want to pay

for and endure a fully sprinkled and detector equipped house

containing no toxic emitting or flammable personal property? Certainly

383
we are reaching for a compromise to limit the life and property losses

but we are a long way from accepting the charge of total elimination.

Since we cannot totally eliminate these losses but can limit them, we must consider so called tradeoffs. If we require or allow

compartmentalization in a high rise building, it should not be also

necessary to totally sprinkle the building. Are we sophisticated

sufficiently to regulate the contents of a building such as furniture,

waste baskets, papers not in fireproof containers, clothes, etc.

Certainly this loading of a so called fire proof building with

flammables and toxic materials creates a problem too lengthy here to

discuss but it is worthy to consider trade-offs with other protective

means

What then single conclusion can be drawn from any of this? Or is

this merely a rambling of unconnected theories, statements, facts and

considerations! I feel that a rationale approach is needed in the

building regulatory process. No longer can we afford to have the

political-irrational approach to building laws and enacted by

legislatures who are lawyers, doctors, barbers, educators, etc.,

enforced by inept building officials making political and/or

irrational decisions in their interpretation, enforcement and

sometimes enactment of building regulations. The Utopian method would

be to discard all present building codes and enter into a marriage

with all specialty groups engaged in the safe occupation of buildings.

These "buildings code" specialists would be charged with not only

drafting a code, which has already been done, but, more importantly in

the case of each regulation, explaining why it is a necessary

regulation. For example, we presently establish the maximum number of

occupants allowable in a place of assembly but we do not consider that

instead of able bodied persons there may be in this same place of

assembly a meeting of wheelchair equipped handicapped persons. If our examination discloses that a hall may have 300 occupants should we allow or prohibit 300 people in wheelchairs from occupying this space?

Why do we regulate the height of the exit doors at 6 '8" when we have

persons today standing over 6 '8", so why not set the requirement of

7 '8" or 8'? And if the door height is required 6*8" minimum, why is

the ceiling height minimum set at 7 '6" and not at 6*8" or 8'? Is the

ceiling height a truly public safety regulation or is it a matter of

public health or merely public convenience? Is the width of the

required exit door set at 36" or 32" for public safety or is it for

purposes of getting furniture or caskets in and out of doorways? I believe the unit of egress width for all approved types of means of

egress parts and facilities is 22" and half the unit is 12", so what

would be the rationale to 32" or 36"? I certainly do not advocate 22"

doors but I do ask, as a public safety requirement, all to consider

how we arrived at the 32" or 36" instead of responding that 36" is far

safer than 34". Consider also if 34" is considered sufficient, would

the additional cost of adding or reducing by 2" the width of the

required exit door be prohibitive? It must be remembered that unlike

any period of time before, public servants must be responsive to the

public which it serves. Today there are consumer groups, tenant

groups, parent teacher organizations, etc., and they want rational

answers. How long can we afford to enforce building laws that have

their beginnings dependent on the political strength of mills,

384
fabricators, insurance companies, construction firms, labor unions,

politicians and in some cases even building officials. If we concede

that a specification oriented code is obsolete and costly, are the

building officials, the technicians, architects and engineers ready

and willing to accept a true performance oriented code? The building

official must be capable of evaluating the results of performance

data; the architect and engineer must be willing to accept a true

performance oriented code. The building official must be capable of

evaluating the results of performance data; the architect and engineer

must be willing to justify his design. Some feel that often the

architect and engineer oppose a truly specification code because the

"tried and true" methods do not result in a great varying degree of

competition. Given the personal requirements of a client for a building, and no building code, how many of us would take on the

responsibility of designing the building with only the consideration

of the client and public safety? We probably would first consider the

safe evacuation of the occupants and if it becomes impossible to

totally evacuate safely the occupants, we would provide for them a so-called area of refuge. I do not believe we are prepared to

eliminate building codes or accept a truly performance oriented

building code but we are sophisticated enough to question each section

of the building code and ask, "why is this a requirement" or "why

cannot the architect or engineer exercise some ingenuity and

imagination in his design?" National organizations such as NCSBCS

must have a voice that can be heard over the irrational designers of

building regulations; a voice that in this technology motivated world

is deserving of a specialists approach to a building regulatory

system.

A LEGAL APPROACH

We must consider the constitutional rights of the individual

which are often opposed by the collective rights of the public. This

delicate balance of the individuals right to the quiet enjoyment of

his property and person has only recently been attacked in the courts.

Consider a building occupied as a place of assembly and built prior to

a building code. Can a building official impose new regulations on

this pre-code building? Consider a new litter law; can one be

prosecuted for littering the streets yesterday when the law was not in

effect until today? This litter law is clearly effective for those

littering after its effective date but the new building code

requirements do not cite the building for being built in violation of

the law but of being in violation of the law (regulation) after its

effective date. Violations of the building and housing codes are continuing violations and not a one incident violation. Building

officials were accused of invading the constitutional guarantee of

Vested Property Rights but the courts have responded that building

code regulations are a proper exercise under the States police power

for the preservation of life, health, and morals. To date, most

building code regulations have survived the test of reasonableness but

have been successfully attacked as to the reasonableness of

enforcement by the building official.

385
If a police officer demanded entry into one's home because he

suspected a member of the neighborhood or household of committing a crime, would we consider it reasonable to allow entry for the official

to search and question our household? I think not very easily. It is

then reasonable for building officials to demand entry into the

non-public portion of a building for purposes of inspection and possibly obtaining evidence to be used against such occupant in a court

of law? In the case of the police officer, the evidence could be

destroyed and the suspect could escape from the area in the time he

needs to get a warrant but still the court requires a warrant be

obtained for entry except in very limited instances. As to the

building officials demanded entrance being denied, and now requiring

him to procure a warrant for a legal search and entrance, the

suspected violator, in the meantime, may leave at any time without any

problem to the building official and if the violation is corrected in

the time it takes to get the warrant, the building official has only

been inconvenienced but should be pleased.

The fourth amendment to the constitution guaranties "...The right

of the people to be secure in their persons, houses, papers, and

effects, against unreasonable searches and seizures ... and no warrant

shall issue, but upon probable cause, supported by Oath and

Affirmation, and particularly describing the place to be searched, and

persons or things to be seized." These protections have been extended

to State proceedings by the fourteenth amendment.

In 1959, the U. S. Supreme Court in Frank vs. Maryland, had to answer an important question - What constitutes an "unreasonable"

search. The court held in a 5-4 decision, that upon being refused

entry to inspect, a warrantless search was not unreasonable since the

evidence obtained was not intended for use in a criminal prosecution

although the refusal to allow entry was punishable criminally. The

majority of the court felt that there is no absolute right to refuse

consent to an inspection designed solely for the protection of the

community's health. In this case, the violation, could be seen without

entry onto the premises of the defendant. In 1960, the same court in

Ohio ex rel Eaton vs. Price heard a similar case but because it was a 4 to 4 decision, the Maryland decision was allowed to stand; the only

significant difference v;as no physical indication of a probable

violation in the Ohio case. All judges held their position but the

ninth judge (Stewart) was from Ohio and took no part in this Ohio

decision. It must be mentioned that he probably would have voted to

affirm the Maryland decision since he so voted with the majority in

that case. In 1967, by a 6-3 vote the court in Camara vs. San

Francisco and See vs. the City of Seattle, reversed the Maryland and

Ohio cases and stated that not only must a warrant be obtained but

without a warrant there must be a voluntary intentional waiver of the

fourth and fourteenth amendment which cannot be gained under the guise

of submittal to an authority (i.e. "in the name of the law" or "under

the color of ones office-his badge"). It is interesting to note that none of the Justices in the Ohio or Maryland cases changed their vote,

but two of the justices who voted against the need for a warrant were

no longer on the court and their replacements voted with the four (4)

voting in favor of requiring the warrant. Do we dare conclude.

386
therefore, that even the Supreme Court of the United States vote their

own personal convictions, and decisions can hang on the make up of the

court? If we read the results of the cases decided we must realize

that a 5-5 or 5-4 or 6-3 decision is not a comfortable margin on the

side of right but it is the best system for reaching an end. An often

forgotten conclusion drawn by this court is very important to code

enforcement officers and that is the authority of building and housing

codes to "...impose and enforce such minimum standards even upon

existing structures" has therein been solidified.

VIOLATIONS OF THE BUILDING CODE

Any building code, like any law or regulation is merely a compilation of requirements necessary to do or to prohibit certain

tasks. As any tool it is best used in the manner for which it has

been designed, or the tool must be designed to do a specific task.

How many of us would adhere to a fifty-five (55) mph speed limit if

there were no enforcing officers watching and threatening reprisal?

We certainly would not push the accelerator to the floor and travel

ninety (90) miles an hour on a windy road only because of a fear for our own personal safety. We would most probably not be as concerned

traveling at seventy (70) mph on a highway. So too with building code

regulations. Without violation penalties and code officials to

enforce them would the construction and maintenance of buildings be

accelerated beyond the point of public safety? I cannot believe that

it would be pushed beyond endurance but I accept the fact that

compliance could be compromised so as to possibly endanger the public;

to believe otherwise would be to forget the need for the original code

requirements and the constant revisions made necessary from time to

time. Building officials must have the power to reasonably enforce

the codes. If a dangerous condition exists in an occupied building in

the middle of a highly congested area is it reasonable to give the

violator thirty (30) days in which to make the necessary corrections?

Conversly if the same conditions exist in an isolated non-occupied

building the thirty (30) days is not so crucial.

Non-compliance with a building code in a majority of the cases is

of little trouble to the building official since most provisions of

the code deal with new construction and the item of non-compliance is so because of the building officials interpretation. If the person

desiring the building permit wants to proceed, he must determine first

if the building official is correct in his interpretation, if so, he

may comply with the code or he may seek a variance or waiver from a higher authority. If he disagrees with the building officials

interpretation, he may comply anyway or appeal such interpretation to

a higher authority, a board of appeals, or the courts. In most

instances it is cheaper to comply. Appeals to a higher authority take

too much time, and time is money. So in 90% to 95% of the cases, we have voluntary compliance in new construction and 5% to 10% of the

non-compliance items are appealed. The important factor not known is

how many cases were incorrectly interpreted and completed the building

officials way, since the applicant could win the battle but lose the

war. He cannot forget that this same building official will later

387
issue the building permit, the certificate of inspections, and the use

and occupancy permit, and in many instances certain licenses.

Perhaps the most troublesome nonconforming cases the building

official deals with are those of existing buildings that are found to

have violations of the building code. If the "violator" is not

seeking a building permit how does the building official receive

compliance on a voluntary basis? If the violator is faced with a political or economic loss he will no doubt try to avoid such loss by

correcting the deficiencies, and we have seen that the loss or threat

of not renewing a license is a great deterent, but what of the

remaining cases where the violator merely stalls the official attempts

to bring political pressure or appeals such rulings to a higher

authority merely to gain time.

What requirements, therefore, of the building code are intended

to apply to existing buildings? Most building codes state that no further requirements may be imposed on an existing building unless the

building official deems them necessary for the general safety and

welfare of the occupants and the public. Since an existing building

must be presumed to have been legally built and nothing about the

building has changed, the building has been maintained in a safe and

sanitary manner, how then can we justify the imposition of added

requirements? It seems the building owner and public need to know

what prompted this change, and a developer also would like to know why more stringent requirements are placed on his building than on the

existing buildings.

I suppose an answer could be that a rural road built in 1930

could have justified in 1930 a speed limit of 45 mph but because that

same road today is not in a rural area, the traffic is far greater;

the vehicles are improved but the risk, or potential risk, is

therefore, far greater and a 30 mph limit is perhaps more reasonable.

In short, the road did not change but other factors have. So too,

must we impose greater restrictions on existing and new buildings and

structures today. No one can doubt that never before have so many

spent so much of their daily lives in buildings and structures. We are not nomads; we eat, sleep, work, and even play in buildings and

structures and we are entitled to be safe at these endeavors even though those charged with the responsibility of seeing to this safety

are not generally acknowledged and appreciated for the tasks they

perform so well. It is most important that the building code regulators keep up with the technology and, where necessary, impose further

regulations on existing buildings and, where possible, allow a relaxation of code requirements determined now to be obsolete or unnecessarily stringent.

Building officials very often are the defendants in suits seeking

to restrain them from certain action or seeking to require them to

take certain action. Many times the building official must resort to

the courts himself in order to get compliance. He can proceed on the

civil side by instituting an action to prevent unlawful construction

or to restrain, correct, or abate a violation, or to prevent illegal

occupancy of a building, structure, or part, thereof, or to stop an

388
illegal act, conduct, business, or use of a building. He may also

institute an action on the criminal side of the court against the

violator if the violation is not corrected "promptly." The courts

have wrestled with the requirement of "promptly" for many years and

have ascertained only that such order of the building official shall

be "reasonable" and therein lies the bigger problem.

What is "reasonable?" Is 24 hours reasonable to contract for a demolition contractor to transport the necessary equipment and

manpower to remove a dangerous wall? Is seven days a reasonable time

to require that an illegal occupancy be removed? Or is thirty days

reasonable in order to remove lead paint from a dwelling unit? It is

unlikely that we can answer without more facts in these cases but the

building official is required to ascertain in what circumstances would

his order be reasonable. In the case of a dangerous wall located in a congested area where demolition people are available, the twenty-four

(24) hours would probably be reasonable. If the dangerous wall is a barn away from everyone and everything, twenty-four (24) hours would

probably be deemed unreasonable.

The frustrations of the building official are greatest in the

process of getting these violations corrected. If he does not get

voluntary compliance with his violation notices, he may have no alternative but to seek from the courts the necessary support.

Unfortunately, by the time he enters the case in court, several days,

weeks, or even months have gone by, so that for that period of time at

least the "violator" has won. When it finally comes to trial, the

court is usually sympathetic but rarely finds the violator guilty of

not complying with the officials order but feels obligated to go

beyond this and require compliance and then dismissal. The court now

wants to hear the background of the case. The violation of the

officials order now seems insignificant. The court will invariably

order the corrections to be made, something the building official has

already attempted, and this adds more days or weeks to the frustrations. Often the building official feels that the courts do not

consider this a crime as compared to a robbery of a person. Consider,

however, that the robbery has already been committed and ordinarily no one is any longer in danger resulting from that crime; and whether the

defendant is tried immediately or in six months will not increase any

hazard to the victim. Now consider the building code violation that

is continuing as though every day the defendant is "robbing" the same victim. Unfortunately, we are unable in a majority of cases to

convince the courts of the severity of building code violations.

ALTERNATIVE CODE ENFORCEMENT TOOLS

Perhaps the building official needs another tool for enforcement.

The building official could prosecute the case before a municipal

administrative tribunal which could access reasonable costs for

noncompliance of the order and could make reasonable orders. The

violator would then have a choice of either compliance or the burden

of appealing the administrative order. If he did neither, he could be

sued on the civil side of the court in order to collect the costs

389
imposed or to enforce the administrative order. It is possible that

any such suit would not require the testimony of the building official

and he would be free to bring another action against the violator

before the administrative tribunal.

Local banks do not print money; they cannot invest or pay

interest on deposits unless they invest the money held on deposit. If

a neighborhood bank holding neighborhood deposits (investors) lends

money for mortgages on local real estate, do they not owe an obligation to its investors (depositors) to protect such investment?

If the investment has deteriorated or is deficient in some way, should

not these banks do something to protect their investors? If these

lending institutions would perform from time to time inspections in

order to protect their investments, they may procure for their

depositors a greater dividend in profits or in property values; such

periodic inspection would also aid the building official in his job

since noncompliance with the mortgagees' order could result in a foreclosure. No other business does as little to watch its

investments in the monthly payments being made, and if there is a loss

of life due to a building code violation, it does not greatly concern

them; if the building becomes vacant or has a fire that, too, does not concern the banks; after all, a fire insurance policy provides for the

proceeds to be paid to the bank so that the asset is protected. What

they have not done is protect their local investors who perhaps live

in the building which is in violation. A building which has

deteriorated to the extent that it has become a liability to the

community is no longer an asset to anyone. Perhaps then we should

consider assessing responsibility on anyone having a substantial

interest in a building or structure.

CONCLUSION

The building regulatory process from its crude beginnings of

responding to disasters has come a long way but such distance has been

traveled most in the past forty years and the greatest distance is yet

to be traveled. We are still well behind technology, technology that

is not yet tough enough to overcome our own questioning. We must be

willing to listen and be able to accept the mandate of the people; we must look for new ways of getting things done and accomplishing

compliance. The courts have placed an obstacle in the path of code

enforcement in requiring certain procedures be followed prior to entry

and inspection but it is not an obstruction at all, only the courts

method of playing catch-up with technology. Technology itself will

not make for a better building regulatory process unless the building

officials are properly and continually trained in the use of their new

technology.

390
ATTENDEES

NBS/NCSBCS JOINT CONFERENCE

ON

RESEARCH AND INNOVATION IN THE BUILDING REGULATORY PROCESS

Aikman, Alastair J. M. Alberta Labour Department

Building Standards Branch

707-10808-99 Avenue

Edmonton, Alberta, CANADA T5K 092

Anderson, Jonna L.

Appell, Donald

Bahr, Russell

Barrow, Don

Beardmore, Charles

Bechtel, Clarence

Becker, Ottmar, President

University of Minnesota

Environmental Health & Safety

Boynton Health Service

W-140 410 Church Street, S.E.

Minneapolis, Minnesota 55455

State of Iowa Building Code Commissioner

523 East Twelfth Street

Des Moines, Iowa 50319

State of California

Department of Housing & Community Development

921 Tenth Street

Sacramento, California 95814

Skyline Corporation

2520 By-Pass Road

Elkhart, Indiana 46514

State of Kansas

Division of Architectural Services

State Office Building

Topeka, Kansas 66612

Building Officials and Code Administrators

International, Inc.

1313 East 60th Street

Chicago, Illinois 60637

Building Officials and Code Administrators

International, Inc.

3700 West 175th Place

Country Club Hills, Illinois 60477

Beha, Ann M. Massachusetts Institute of Technology

Room 7-301

Cambridge, Massachusetts 02139

Berntsen, Robert State of New Mexico

Construction Industries Commission

P.O. Drawer 5155

Santa Fe, New Mexico 87503

391
ATTENDEES

Betts, Douglas

Bickle, Larry, Director

Blair, John, Chief

Architect

Brown, Thomas B.

Bryant, Willard E.

Buchan, Rod B.

Bullock, George H.

Bullock, Richard

Burba, Francis

Cabelus, Bernard

Campbell, Walter

Carr, Donald

Carter, T. H. , Executive

Director

I

1 Fleetwood Enterprises, Inc. ; P.O. Box 7638 I Riverside, California 92523 '

Division of Energy Conservative Design i University of New Mexico

Albuquerque, New Mexico 87106 i

State of Missouri | P.O. Box 809 , Jefferson City, Missouri 65101 '

Pennsylvania State University

Department of Architectural Engineering i University Park, Pennsylvania 16802 {

! State of Maryland Codes Administration \ 1748 Forest Drive i Annapolis, Maryland 21403 ^

National Forest Products Association

1619 Massachusetts Avenue, N.W.

Washington, D.C. 20036

State of Georgia

P.O. Box 431 i Athens, Georgia 30603

I Department of Industry, Labor and Human

Relations

j P.O. Box 7946 I Madison, Wisconsin 53707 j Department of Public Health ] 535 West Jefferson

j Springfield, Illinois 62761

j

j State of Connecticut

30 Winchell Drive

Kensington, Connecticut 06037

| State of Washington

Department of Labor and Industries

General Administration Building ' Olympia, Washington 98504 '

National Association of Home Builders '• 15th & M Street, N.W. • Washington, D.C. 20007

International Conference of Building Officials ; 5360 South Workman Mill Road

j Whittier, California 90601 |

392
ATTENDEES

Church, Kern

Cirillo, Joseph

Cooke, Patrick W.

Cuba, Joseph F. , Director

of Research and Technical

Services

Cummins, Gary

Decker, Charles M.

Dickens, H. Brian

Dierdorff, Jack L. President

Dinezio, Charles J.,

First Vice President.

NCSBCS

State of North Carolina

1217 Trailwood Drive

Raleigh, North Carolina 27606

State of Rhode Island Building Commission

12 Humbert Street

North Providence, Rhode Island 02911

Center for Building Technology

Building 226, Room B226

National Bureau of Standards

Washington, D.C. 20234

American Society of Heating, Refrigerating

and Air-Conditioning Engineers, Inc.

United Engineering Center

345 East 47th Street

New York, New York 10017

T. R. Arnold & Associates, Inc.

P.O. Box 1081

Elkhart, Indiana 46514

State of New Jersey

Department of Community Affairs

620 West State Street

Trenton, New Jersey 08625

Division of Building Research

Codes and Standards Group

National Research Council of Canada

Ottawa, Ontario, CANADA, KIA 0R6

Building Owners & Manufacturers Association

International

1221 Massachusetts Avenue, N.W.

Washington, D.C. 20005

Executive Director

State Building Code Commission

John W. McCormack State Office Building

Room 1305, One Ashburton Place

Boston, Massachusetts 02108

Dobson, Clinton

Administrator

Dowd, Gaylord, Past

President

Office of the State Fire Marshal

8941 Jefferson Highway

Baton Rouge, Louisiana 70809

International Conference of Building Officials

5360 S. Workman Mill Road

Whittier, California 90601

393
ATTENDEES

Bowling, James R.

Dritt, James, Senior

Research Associate

Duncan, Arthur F.

Early, Rex

Eder, Vernon

Edwards, C. Morgan

Erlckson, Glenn, First

Vice President

Fafard, Charles H.

Field, Charles

Fitch, William

Flanagan, Earl

American Institute of Architects

1735 New York Avenue, N.W.

Washington, D.C. 20006

New Mexico Energy Institute at the

University of New Mexico

Albuquerque, New Mexico 87106

American Institute of Architects

1735 New York Avenue, N.W.

Washington, D.C. 20006

Virginia State Fire Marshal's Office

P.O. Box 1157

Richmond, Virginia 23209

State of Indiana Administrative Building

Council

300 Graphic Arts Building

215 N. Senate Avenue

Indianapolis, Indiana A6204

Industrialized Housing Manufacturers

Association

P.O. Box 710

Harrisburg, Pennsylvania 17108

Building Officials and Code Administrators

International, Inc.

1313 West 60th Street

Chicago, Illinois 60637

Wisconsin Department of Industry, Labor,

and Human Relations

Madison, Wisconsin 54750

Real Estate Practices

Department of Housing and Urban Development

451 Seventh Street, S.W., Room 4222

Washington, D.C. 20410

Owens-Corning Fiberglas Corporation

Fiberglas Tower

Toledo, Ohio 43659

Department of Housing and Urban Development

451 Seventh Street, S.W.

Washington, D.C. 20410

394
ATTENDEES

Flint, William

Fordham, Paul

Foreman, Byron L.

Goforth, George T.

Gough, Marvin

Green, Melvyn

Gross, James G.

Groves, Jr. , John R.

Harris, James R.

Hart, Michael

Hartell, Ken

Hauck, Richard

American Plywood Association

1119 A Street

Tacoma, Washington 98401

State of Utah Department of Business

Regulation, Mobile Homes and Recreation

Vehicle Division

330 East 400 South

Salt Lake City, Utah 84111

Western Wood Products Association

Yeon Building

Portland, Oregon 97204

Defense Civil Preparedness Agency

General Engineering Division

Washington, D.C. 20301

American Hospital Association

840 North Lake Shore Drive

Chicago, Illinois 60611

Melvyn Green and Associates, Inc.

690 North Sepulveda Boulevard

Suite 120

El Segundo, California 90245

National Bureau of Standards

Building 226, Room B226

Washington, D.C. 20234

University of Kentucky

Lexington, Kentucky 40506

National Bureau of Standards

Building 226, Room B226

Washington, D.C. 20234

Energy Engineering Associates, Inc.

Austin, Texas 78701

Boise Cascade Corporation

One Jefferson Square

Boise, Idaho 83728

State of Minnesota

408 Metro Square Building

7th & Robert Streets

St. Paul, Minnesota 55101

395
ATTENDEES

Hawkins, Jasper S.

Heerwagon, Dean R,

Heilstedt, Paul K.

Heron, Jane

Hicks, Jr., James

Hilprecht, Robert C

Hogan, John

Holtz, Michael

Isom, Allie 0.

Jacobson, Trevor

Jensen, Lee

Hawkins & Lindsey Architects

111 East Camelback Road

Phoenix, Arizona 85012

University of Washington

Seattle, Washington 98195

Portland Cement Association

5420 Old Orchard Road

Skokie, Illinois 60076

Housing Programs Coordinator

Illinois Department of Local Government

Affairs

160 N. LaSalle Street, Room 300

Chicago, Illinois 60601

National Bureau of Standards

Building 226, Room B226

Gaithersburg , Maryland 20760

Michigan Department of Labor

Bureau of Construction Codes

State Secondary Complex

7150 Harris Drive

Lansing, Michigan 48909

City of Seattle Energy Office

914 Arctic Building

Seattle, Washington 98104

American Institute of Architects/Research

Corporation

1735 New York Avenue, N.W.

Washington, D.C. 20006

Oklahoma State Board of Public Affairs

Room 306, State Capitol Building

Oklahoma City, Oklahoma 73105

Oregon State Department of Commerce

Building Codes Division

401 Labor & Industries Building

Salem, Oregon 97310

Building & Safety Inspection

City of Flint

1101 S. Saginaw

Flint, Michigan 48502

396
ATTENDEES

Jewell, Clark E. Administrator

Jolly, Fred

Jones, Ray

Kelley, Alex C.

Koch, Gerhard

Kornsand, Norman J. Assistant Vice President

LeCain, Bob

Liepins, Gunar E.

Lowrey, Dennis

Lucht, David, Deputy

Administrator

MacRae , Donald

Guam Energy Office

P.O. Box 2950

Agana, Guam 96910

Nebraska State Health Department

Division of Housing & Environmental Health

301 Centennial Mall South

Lincoln, Nebraska 68509

Division of Mobile & Manufactured Housing

Standards

1645 West Jefferson

Phoenix, Arizona 85007

Georgia State Building Administrative Board

166 Pryor Street, S.W.

Atlanta, Georgia 30303

International Business Machines

Real Estate & Construction Division

1000 Westchester Avenue

White Plains, New York 10604

Rolf Jensen & Associates, Inc.

Deerfield, Illinois 60015

U.S. Forest Service

Department of Agriculture

Northern Region Federal Building

Missoula, Montana 59801

Oak Ridge National Laboratory

Box X, Room G-24, 4500 North

Oak Ridge, Tennessee 37830

Portland Cement Association

Suite 710, 1385 South Colorado Boulevard

Denver, Colorado 80222

National Fire Prevention and Control

Administration

P.O. Box 19518

Washington, D.C. 20036

State Building Commissioner

300 Graphic Arts Building

215 North Senate Avenue

Indianapolis, Indiana 46204

397
ATTENDEES

Mahaffey, Charles

Mann, C. Curtis, P.E.

Chief Mechanical

Engineer

Manning, William

Mara, Gerald

Mason, John

McLain, William H.

Mendoza, Xavier

Milton, Hans J., FRAIA,

Assistant Secretary for

Housing Research

Mittelmark, Melvin F.

Moore, D. W.

Moran, D. F. , Project

Manager

National Bureau of Standards

Building 226, Room B226

Washington, D.C. 20234

Department of Safety and Permits

City of New Orleans

New Orleans, Louisiana 70101

Southern Building Code Congress

International, Inc.

3617 Eighth Avenue

Birmingham, Alabama 35222

National Solar Heating and Cooling

Information Center

Rockville, Maryland 20801

Office of Mobile Home Standards

Department of Housing and Urban Development

451 Seventh Street, S.W., Room 4222

Washington, D.C. 20410

Southwest Research Institute

8500 Culebra Road

San Antonio, Texas 78284

Department of Housing & Community Development

Division of Codes and Standards

921 10th Street

Sacramento, California 95814

Australian Department of Environment,

Housing and Community Development

National Bureau of Standards

Building 226, Room B226

Washington, D.C. 20234

Honeywell, Inc.

MN17-T113, 2600 Ridgway Parkway

Minneapolis, Minnesota 55413

Southern California Edison Company

P.O. Box 800

Rosemead, California 91770

Earthquake Engineering Research Institute

112 Gay Drive

Ventura, California 93003

398
ATTENDEES

Morgan, Elmo R.

Moriarty, Paul J.

Mullen, C. Sutton

Nelson, Forrest

Nelson, Harold E.

,

Director

Nightingale, Richard

Oliver, Raymond

Omson, Henry, Vice

President

Osterby, Norman R.

Pitts, Travis

Printy, James

National Association of College and

University Business Officers

1928 Ptarmigan #1

Walnut Creek, California 94595

Massachusetts State Building Code Commission

1 Ashburton Place, Room 1305

Boston, Massachusetts 02108

State Fire Marshal

P.O. Box 1157

Richmond, Virginia 23209

Southern Building Code Congress

International, Inc.

P.O. Box 3827

Beaumont, Texas 77704

Accident and Fire Prevention Division

General Services Administration

Public Building Service

18th & F Streets, N.W.

Washington, D.C. 20405

University of Maine

118 Boardman Hall

Orono, Maine 04473

Louisiana Department of State Fire Marshal

109 State Office Building

325 Loyola Avenue

New Orleans, Louisiana 70112

Manufactured Housing Institute

Technical Services

1745 Jefferson Davis Highway, Suite 511

Arlington, Virginia 22202

Department of Administration

50 Sherburne Avenue

St. Paul, Minnesota 55155

RADCO

P.O. Box 5506

Carson, California 90749

Consultant

9610 Jonquil

Westminster, California 92683

399
ATTENDEES

Reeder, Belinda American Institute of Architects/

Research Corporation

1735 New York Avenue, N.W.

Washington, D,C. 20006

Remmer, Norton S. Commissioner

Robinson, Chandler

Robinson, Courtney E.

Schoonover, Kenneth

Department of Code Inspection

Worcester, Massachusetts 01601

State Fire Marshal's Office

Third Floor, Plaza

Capitol Tower Building

Frankfort, Kentucky 40601

Administrative Building Council

Room 300, Graphic Arts Building

215 North Senate

Indianapolis, Indiana 46204

Building Officials and Code Administrators

International, Inc.

1313 East 60th Street

Chicago, Illinois 60637

Schwinden, Ted

Lieutenant Governor

Sepsy, Charles

State of Montana

State Capitol

Helena, Montana 59601

American Society of Heating, Refrigerating

and Air Conditioning Engineers

206 West 18th Avenue, Robinson Laboratory

Ohio State University

Columbus, Ohio 43210

Shields, James W.

Shivar, James F. , Program

Manager

Sluiter, Thomas

Department of Community Affairs

Division of Industrailized and Mobile Homes

P.O. Box 155

Room 500, State Office Building

Harrisburg, Pennsylvania 17102

Division of Buildings and Community System

U.S. Energy Research and Development

Administration

Washington, D.C. 20545

Construction Research Council

1000 Vermont Avenue, N.W.

Washington, D.C. 20005

400
ATTENDEES

Smith, Robert B.

Smith, Robert L. , P.E.

Smith, William

Smyrl, Elmira

Spence, James C.

Starostovic, Ed

Stock, Marvin

Stoppelman, Louis

Swanson, Gayle G.

Swenson, Glen R.

,

President, NCSBCS

Taugher, Victor

Thurber, Delmont C. Chairman

Secretary/Treasurer, NCSBCS

National Fire Protection Association

Suite 570-South, 1800 M Street, N.W.

Washington, D.C. 20036

University of Illinois

Department of Architecture

Urbana, Illinois 61801

Underwriters Laboratories, Inc.

333 Pfingsten Road

Northbrook, Illinois 60062

Montana State University

Bozeman, Montana 59715

American Iron and Steel Institute

1000 16th Street, N.W.

Suite 402

Washington, D.C. 20036

Product Fabrication Service

2402 Daniels Street, R.R.5

Madison, Wisconsin 53704

State of Missouri

P.O. Box 809

Jefferson City, Missouri 65101

Division of Buildings & Inspections

1200 Market Street, Room 426

St. Louis, Missouri 63103

Maine State Housing Authority

P.O. Box 1450

Portland, Maine 04104

Utah State Building Board

124 State Capitol

Salt Lake City, Utah 84114

International Conference of Building Officials

5360 South Workman Mill Road

Whittier, California 90601

Montana Building Codes Advisory Council

3815 5th Avenue South

Great Falls, Montana 59405

401
ATTENDEES

Tovey, Henry, Director of

Planning

Trant, B. Shep

Tucker, Ray, Vice

President

Twitchell, Archie

Tyrrell, Joseph V.

Vasvary, William G.

Vyverberg, John

Wanzek, Vince

Wenning, John

Second Vice President

NCSBCS

Werner, Richard J. President

Wiedl, Mary A.

Winter, Steven

National Fire Prevention and Control

Administration

P.O. Box 19518

Washington, D.C. 20036

Council of American Building Officials

2233 Wisconsin Avenue, N.W.

Washington, D.C. 20007

Guerdon Industries, Inc.

P.O. Box 1259

Louisville, Kentucky 40201

National Association of Counties

Research Foundation

1735 New York Avenue, N.W.

Washington, D.C. 20006

Naval Facilities Engineering Command

Alexandria, Virginia 22301

Southern Building Code Congress International

3617 Eighth Avenue, South

Birmingham, Alabama 35222

Owen-Corning Fiberglas Corporation

717 Fifth Avenue

New York, New York 10022

Fleetwood Enterprises, Inc.

3125 Myers Street

P.O. Box 7638

Riverside, California 92523

Department of Industry, Labor and Human

Relations

Safety and Buildings Division

P.O. Box 7946

Madison, Wisconsin 53707

Hilborn, Werner, Carter & Associates

1627 South Myrtle Avenue

Clearwater, Florida 33516

National Center for Appropriate Technology

P.O. Box 3838

Butte, Montana 59701

Steven Winter Associates

475 Park Avenue, South

New York, New York 10016

402
ATTENDEES

NCSBCS Staff: Donald F. Pinkerton

Executive Director

Henry Wakabayashi

Energy Program Director

Charles E. Talmage

Mobile Home Program Director

Dan Brames

Assistant Mobile Home Program Director

Patricia King

Controller

Robert Wible

Information Director

Chris Evans

State Coordinator

Ashwani Dhalwala

Chief Engineer

Debbie Barbe

Secretary

Evelyn Zimmerman

Secretary

403
NBS-114A (REV. 11-771

U.S. DEPT. OF COMM. BIBLIOGRAPHIC DATA

SHEET

1. PUBLICATION OR REPORT NO. NBS SP 5182. Gov't Accession

No.

3. Recipient's Accession No.

4. TITLE AND SUBTITLE RESEARCH AND INNOVATION IN THE BUILDING REGULATORY PROCESS —

PROCEEDINGS OF THE SECOND NBS/NCSBCS JOINT CONFERENCE

5. Publication Date August 1978

6. Performing Organization Code

7. AUTHOR(S)

Patrick W. Cooke, Editor

8. Performing Organ. Report No.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, D.C. 20234

10. Project/Task/Work Unit No.

11. Contract/Grant No.

12. Sponsoring Organization Name and Complete Address (Street, City, State, ZIP)

U.S. Department of Conmerce, National Bureau of Standards

and National Conference of States on Building Codes and

Standards (NCSBCS)

13. Type of Report & Period Covered Final

14. Sponsoring Agency Code

15. SUPPLEMENTARY NOTES

16. ABSTRACT (A 200-word or less factual summary of most sigfiilicant information. If document includes a significant bibliography or literature survey, mention it here.)

The Second NBS/NCSBCS Joint Conference on Research and Innovation in the Building

Regulatory Process was held in Bozeman, Montana on September 20, 1977. The proceedings contain the 25 papers presented at the eight technical sessions. The technical

sessions addressed the following issues:

- Implementation of Solar and Energy Conservation Building Standards

- Issues in Building Regulation

- Considerations in the Development of Energy Conservation Building Standards

- Developing New Approaches for Formulating Building Regulations

- State Experiences in the Development of Energy Conservation Building Standards

- The Expanding Role of the Building Official

- Application and Impact of Building Energy Conservation Standards

- Administration of Building Regulations

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only tfie first letter of the first key word unless a proper name; separated by semicolons)

Administrative procedures; buildings; building codes; building regulations;

economic impacts; environmental considerations; innovative practices;

regulatory research; standards development.

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(THIS REPORT)

UNCLASSIFIED

20. SECURITY CLASS

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UNCLASSIFIED

21. NO. OF PAGES;

406

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