( • DOE F , 325 .8 

(08-93) 

United States Government Department of Energy 

m·emorandum ffl3 

REPLY TO 

ATTN OF: 

SUBJECT: 

TO: 

EE-91 (YI. Prue, 6-4537) 

Title 10, Code of Federal Regulations, Parts 434 and 435, Energy Code for New Federal 

Commercial and Multi-Family High Rise Residential Buildings; Proposed Rule 

·Energy Code for Federal Commercial Buildings, Docket No. EE-RM-79-112-C, Buildings 

Division, EE-431, Office of Codes and Standards 

We have reviewed the subject proposed rule and detailed comments are provided in the 

attachment. We applaud using the codified version of the American Society of Heating, 

Refrigerating and Air-conditioning Engineers Standard 90.1, Energy Efficient Design of New 

Buildings Except New Low-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 better to use the codified version of ASHRAE 90. l, with exceptions 

for Federal buildings specified as needed, rather than publishing an entirely new rule. This 

should make the transition to Federal buildings design easier for NEs. 

If you have any questions, please contact Will Prue on (202) 586-4537. 

~C~c/ ~ru: ~~~bald, Deputy Director 

Federal Energy Management Program 

Energy Efficiency and Renewable Energy 

@ Printed on r&eyelad paper 
. ~ 

MAJOR.COMMENTS- 10 CFRPARTS 434AND 435 

FEDERAL ENERGY MANAGEMENT PROGRAM 

Attachment 

1. Section 434 .102, Compliance - This section requires certification by a registered architect 

or engineer for 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 of Subpart D. Without an enforcement mechanism, 

ensuring that design and construction meet performance standards, as required by 

Section 306 of Executive Order 12902, Energy Efficiency and Water Conservation at 

Federal Facilities, will be·a problem. 

2. Table 401.3.2a - INTERIOR LIGHTING POWER 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/Ff2

, 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 in the proposed rule will not help the Federal government be a 

leader in energy efficiency. More stringent allowances should be considered for this 

rulemaking. 

3. Table 403.la- 403.lf-These tables appear to be modest in terms of energy efficiency. 

For example, the most stringent chiller full load coefficient ofperfonnance is 5.2, which 

eql,lates to 0.676 kilowatts per ton (kW/ton). New chillers are being manufactured which 

have ratings of 0.50 kW/ton, and lower. We would like to draw your attention to the 

requirements of Section 507 of Executive 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 of energy efficiency for all similar products, or products that are at least 

10 percent more efficient than the minimum level that meets Federal standards." To help 

agencies comply, the Federal Energy Management 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 by FEMP 

EDITORIAL COMMENTS 

I. Section 401 .3, Lighting Power Allowance-This section should follow the columnar 

format used for the rest of the proposed rule. 
. .. . . 

2. Table 401.3.2d - UNIT INTERIOR LIGHTING POWER ALLOWANCE - This table is 

incomplete. Only a small portion of the table has been printed. 

l. Paragraph 402.3 .1 ( d) - The part in parenthesis is confusing. It appears 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 of design air volume, based on 

manufacturer's test data." Since power is proportional to volume cubed, required power 

at 50 percent volume is only 12.5 percent of design. Even accounting for lower motor 

and fan efficiencies at lower flow rates, the 50 percent of design wattage figure seems 

high. . 

5. Equation 508.1 and 508.1.2 - These equations appear to have numerous errors: 

0 

0 

0 

0 

0 

It appears that "DECOSmdcc: .. should be "DECOSc1ac" 

It appears that ''DECOS2." should be "DECOS." 

It appears that "DECON m 1" should be "DECON ml " 

It appears that "ECOS " should be "ECOS " lm ml 

It appears that "ICONmi" should be "DECONmi" 

6. Paragraph 514.2 -The first 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 -The footnote refers to Table 513.3, which appears to be in error. Should 

this be Table 512.2? 

9. Table 517.4.1, HVAC SYSTEM DESCRIPTION FOR PROTOTYPE AND 

REFERENCE BUILDINGS - The table is split into two pages. It would read easier on 

one page in the final. 

10. Equation 601.2 - It appears that the equation should be: