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### United States Government Department of Energy 

# m· emorandum ffl 3

REPLY TO ATTN OF: SUBJECT:

TO : EE-91 (YI. Prue, 6-4537) Title 10, Code ofFederal Regulations, Parts 434 and 435, Energy Code for NewFederal Commercial and Multi-Family High Rise Residential Buildings; Proposed Rule

·Energy Code for Federal Commercial Buildings, DocketNo. EE-RM-79-112-C, Buildings Division, EE-431, Office ofCodes and Standards We have reviewed the subject proposed rule and detailed comments are provided in the attachment. We applaud using the codified version ofthe American Society ofHeating, Refrigerating and Air-conditioning Engineers Standard 90.1, Energy Efficient Design ofNew Buildings Except NewLow-Rise Residential Buildings (ASHRAE 90.1). We believe that using this commercial standard will improve compliance, since the architect-engineer (AIE) community is more accustomed to using it than the existing Federal standard. However, we believe that it would be betterto use the codified version ofASHRAE 90.l, with exceptions for Federal buildings specified as needed, ratherthan publishing an entirely new rule. This should make the transition to Federal buildings design easier for NEs. If

you have any questions, please contactWill Prue on (202) 586-4537
.

# ~C~c/**~ru: ~~~bald,**  DeputyDirector Federal EnergyManagement Program EnergyEfficiency and Renewable Energy



# @ Printed on r&eyelad paper

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MAJOR
.COMMENTS- 10 CFRPARTS 434AND 435 FEDERAL ENERGY MANAGEMENT PROGRAM Attachment

1. Section 434.102, Compliance

- This section requires certification by a registered architect orengineerfor buildings designed and constructed to meet the alternative requirements of subparts E or F. There should be a requirement to certify buildings designed and constructed to meet the requirements ofSubpart D. Without an enforcement mechanism, ensuring that design and construction meet performance standards, as required by Section 306 ofExecutive Order 12902, Energy Efficiency and Water Conservation at Federal Facilities, will be· a problem. 2. Table 401.3.2a

- INTERIORLIGHTINGPOWER ALLOWANCE Watts per square foot (WIFT2)- The table uses the 1988 figures from the intetjm rule (10 CFR 435).**Thes~** allowances are not very energy efficient, considering the current technology. For instance, the lowest figure for offices is 1.5 W/Ff 2
, for gross lighted areas over 250,000 square feet. Figures for smaller spaces are less stringent. Designs for new buildings are in the 1.9 W/FT2 range, while maintaining quality lighting for occupants. Using task lighting, even lower power levels can be achieved without compromising lighting quality. The lighting power allowances inthe proposed rule will not help the Federal government be a leader in energy efficiency. More stringent allowances shouldbe considered for this rulemaking. 3. Table 403.la- 403.lf-Thesetables appear to be modest in terms ofenergy efficiency. For example, the most stringent chiller

### full load coefficient ofperfonnance is 5.2, which eql,lates to 0.676 kilowatts perton (kW/ton). New chillers are being manufactured which have ratings of0.50 kW/ton, and lower. We would like to draw your attention to the requirements of Section 507 ofExecutive Order 12902, Energy Efficiency and Water Conservation at Federal Facilities, ofMarch 8, 1994. This section directs Federal agencies to purchase, to the extent practical and cost-effective, "products that are in the upper 25 percent ofenergy efficiency for all similarproducts, orproducts that are at least 10 percent more efficient 

### than the minimum level that meets Federal standards." To help agencies comply, the Federal EnergyManagement Program (FEMP) is currently preparing efficiency recommendations for selected products that are widely purchased in the Federal government. Where·such equipment is also covered by minimum efficiency levels in this proposed new building standard, these levels should be consistent with Executive Order 12902 and the recommendations being defined byFEMP
EDITORIAL COMMENTS I. Section 401
.3, Lighting PowerAllowance-This section should follow the columnar format used for the rest ofthe proposed rule.

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2. Table 401.3.2d

- UNIT INTERIORLIGHTING POWER ALLOWANCE

- This table is incomplete. Only a small portion ofthe table has been printed. l. Paragraph 402.3.1(d)

- The part in parenthesis is confusing. Itappears that it would read more clearly as, "Use 0.70 for**HOD~** 8000 and 0.45 for HOD> 8000
..." 4. Paragraph 403.2.4.3

- The paragraph states, "Individual VAV fans with motors 75 hp and larger shall include controls and devices necessary for the fan motor to demand no more than 50 percent of**d~ign** wattage at 50 percent ofdesign air volume, based on manufacturer's test data." Since poweris proportional to volume cubed, required power at 50 percent volume is only 12.5 percent ofdesign. Even accounting for lower motor and fan efficiencies at lowerflow rates, the 50 percent ofdesign wattage figure seems high.
. 5. Equation 508.1 and 508.1.2

- These equations appear to have numerous errors:
0 0 0 0 0 Itappears that "DECOSmdcc:
.. should be "DECOSc1ac" It appears that ''DECOS2." should be "DECOS." Itappears that "DECON 1" should be "DECON " m ml Itappears that "ECOS " shouldbe "ECOS " lm ml It appears that "ICONmi" shouldbe "DECONmi" 6. Paragraph 514.2 -Thefirst sentence refers to Table 513.2.2, which appears to-be in error. Should this be Table 513.2.b? 7. Paragraph 515.2 refers to Table 513.2, which appears to be in error. Should this be Table 513.2.b? 8. Table 515.2 -Thefootnote refers to Table 513.3, which appears to be in error. Should this be Table 512.2? 9. Table 517.4.1, HVAC SYSTEMDESCRIPTIONFORPROTOTYPE AND REFERENCE BUILDINGS

- The table is split into two pages. Itwould read easier on one page in the 

### final. 10. Equation 601.2

- Itappears that the equation should be: