Response to Comments on 

Preliminary Analyses Supporting DOE'S Determination 

Regarding ANSI/ASHRAE/IESNA Standard 90.1-1 999 

October 19,2001 

Office of Building Technology State and Community Program 

U.S. Department of Energy 

 6450-01-P COMMENT 18
Response to Comments on 

Preliminary Analyses Supporting DOE'S Determination 

Regarding ANSIIASHRAEIIESNA Standard 90.1-1999 

Table of Contents 

I . Introduction ................................................................. 1- 

A . Legislative Background ................................................... -1- 

B . Public Hearing and Initial Comments on Methodology .......................... -1- 

C . Comments on Preliminary Quantitative and Textual Analyses ..................... -2- 

D . Numbering and Identification of Comments and Responses ....................... -2- 

I1 . Comments and Responses ..................................................... -2- 

1 . Comments by Gersil Kay, Conservation Lighting International ..................... -2- 

1.1. Future Standard ..................................................... -2- 

1.2. Luminaire ......................................................... -3- 

1.3. Efficient lighting systems ............................................. -3- 

1.4. Book on fibre optics ................................................. -3- 

1.5. Americans behind in lighting .......................................... -3- 

2 . Comments by S . Gregg Johnson, Johnson, Spellman & Associates .................. -4- 

2.1. Delay in making determination ......................................... -4- 

2.2. State hesitation to adopt the 1999 edition ................................. -4- 

3 . Left blank for consistency with internal working documents ....................... -5- 

4 . Comments by Stuart Cowen, Building Code Commission, ........................ -5- 

4.1. Delay in making a determination ....................................... -5- 

5 . Comments by Susan Coakley, Northeast Energy Efficiency Partnerships, lnc ......... -5- 

5.1. Analysis reasonable and assessment correct .............................. -5- 

5.2. Delay in making a determination ....................................... -6- 

6 . Comments by Randall Lloyd, Vermont Department of Public Service .............. -6- 

6.1. Introductory statement ............................................... -6- 

6.2. Agreement with assessment ........................................... -7- 

6.3. Request immediate action ............................................ -7- 

7 . Comments by John Hogan, Seattle Dept . of Design, Construction, and Land Use ...... -9- 

7.1. Envelope criteria for "lodging." ........................................ -9- 

7.2. Elevators .......................................................... -9- 

7.3. Exterior lighting ................................................... - 10- 

7.4. Parking lighting ................................................... - 10- 

7.5. Parking ventilation ................................................. - 11- 

8 . Comments by David Weitz, Massachusetts Board of Building Regulations and Standards 

..................................................................... 12- 

8.1. Conclusions reasonable ............................................. - 12- 

8.2. Achievable standard ................................................ -12- 

8.3. Encourage timely, positive determination ............................... - 12- 

 6450-01-P COMMENT 18
8.4. Standard covers existing buildings ...................................... 13- 

8.5. Support positive determination. concerned about delay ..................... -13- 

9 . Comments by James E . Wolf. President of the American Society of Heating Refrigerating 

and Air-Conditioning Engineers (ASHRAE) and Martyn Timmings. President of the 

Illuminating Engineering Society of North America (IESNA) .................... 13- 

9.1. Support Standard 90.1 process ......................................... 13- 

9.2. PNNL, Analysis .................................................... 14- 

9.3. Analysis well done, conservative and supports positive determination ......... -14- 

9.4. Existing buildings impact ............................................ -14- 

9.5. Endorse results of analysis ........................................... -15- 

10 . Comments by David Goldstein, Natural Resources Defense Council .............. -15- 

10.1. Introduction ....................................................... 5- 

10.2. Adequacy of standard and standards process ............................ -15- 

10.3. Analysis conclusion correct ......................................... -16- 

10.4. Significant improvements ........................................... -16- 

10.5. Alternative analysis ............................................... -16- 

10.6. Significant improvements to Standard 90.1 possible ...................... -17- 

10.7. Small positive improvement ......................................... -17- 

1 0.8. DOE should advocate further improvements ............................ -17- 

10.9. Federal standards ................................................. -17- 

1 1 . Comments by Robert Hemphill, Gas Technology Institute ...................... -18- 

1 1.1. Introduction and background ........................................ -18- 

1 1.2. Scope - Existing buildings .......................................... -19- 

1 1.3. Subjective analysis ................................................ -20- 

1 1.4. Performance versus prescriptive compliance path ........................ -21- 

1 1.5. Existing buildings ................................................. -22- 

1 1.6. Interior lighting power ............................................. -23- 

1 1.7. Exterior lighting power ............................................. -24- 

1 1.8. Interior lighting controls ............................................ -25- 

1 1.9. Exit signs ....................................................... -26- 

1 1.10. Interior lighting power ............................................ -26- 

1 1.1 1 . Interior lighting power - space by space .............................. -27- 

1 1.12. Envelope air leakage ............................................. -36- 

1 1.13. Speculative building envelopes ..................................... -37- 

1 1.14. Envelope thermal transmittance in cold climates ........................ -37- 

11.15. Skylight thermal transmittance and solar heat gain ...................... -37- 

1 1.16. Slab-on-grade and below grade wall insulation ......................... -38- 

1 1.17. Roof Thermal Transmittance ....................................... -38- 

1 1.18. Floors over unconditioned spaces ................................... -42- 

1 1.19. Opaque wall thermal transmittance .................................. -42- 

1 1.20. Window thermal transmittance and solar heat gain ...................... -43- 

11.21. Opaquedoors ..................................................... 4- 

1 1.22. Load calculations and sizing ....................................... -44- 

11.23. Separate Air Distribution Systems ................................... -45- 

 6450-01-P COMMENT 18
1 1.24. Temperature controls ............................................. -45- 

1 1.25. Off-hour controls and setback ...................................... -45- 

1 1.26. Radiant Heating ................................................. -46- 

1 1.27. Pipe and duct insulation ........................................... -46- 

1 1.28. Completion requirements .......................................... -47- 

1 1.29. Simultaneous heating and cooling controls ............................ -47- 

1 1.30. Economizer controls .............................................. -47- 

1 1.3 1 . Temperature reset controls ......................................... -48- 

1 1.32. Hot gas bypass reduction .......................................... -49- 

1 1.33. Heating, ventilation and air-conditioning equipment ..................... -49- 

11.34. Service water heating equipment efficiency ........................... -50- 

1 1.35. Conclusion about detailed textual analysis ............................ -51- 

1 1.36. Exclusions ..................................................... -51- 

1 1.37. Energy cost budget compliance method ............................... -52- 

11.38. Non-codelanguage ...............................................-5 3- 

Comments by James A . Ranfone, American Gas Association .................... -53- 

12.1. Department of Energy legislated responsibilities ......................... -53- 

12.2. Peer review of analysis ............................................. -55- 

12.3. Market impact of fuel choice ........................................ -55- 

12.4. Market share of space and water heating equipment ...................... -55- 

12.5. Future factors .................................................... -56- 

12.6. Energy consumption forecast ........................................ -56- 

12.7. Interior lighting power requirements .................................. -56- 

12.8. Interior lighting power allowances .................................... -57- 

Comments by Jeffrey Johnson, New Buildings Institute ........................ -64- 

13.1. Support the Department's determination ............................... -64- 

13.2. Opportunities for improving the standard .............................. -64- 

Appendix A 

Invitation to Comment ............................. 

Appendix B 

Web Site Invitation to Comments ............................................. -68- 

 6450-01-P COMMENT 18
I. Introduction 

This document contains comments from a limited set of interested parties regarding draft 

preliminary analyses supporting the Department of Energy's determination regarding 

ANSIIASHRAEIIESNA Standard 90.1 - 1999, Energy Standard for Buildings Except Low-Rise 

Residential Buildings. It also contains our response to these comments. The preliminary 

analyses were posted on the web February 7, 2001, at: http:llwwt~.eren.doe.gov/buildings/ 

codes~standards/buildings/com~determinations. html. 

A. Legislative Background 

Title I11 of the Energy Conservation and Production Act, as amended (ECPA), provides 

that whenever the Standard 90.1-1989, or any successor to that code, is revised, the Secretary 

must make a determination, not later than 12 months after such revision, whether the revised code 

would improve energy efficiency in commercial buildings and must publish notice of such 

determination in the Federal Register. 42 U.S.C. 6833 (b)(2)(A). The Secretary may determine 

that the revision of Standard 90.1-1989, or any successor thereof, improves the level of energy 

efficiency in commercial buildings. If so, then not later than two years after the date of the 

publication of such affirmative determination, each State is required to certify that it has reviewed 

and updated the provisions of its commercial building code regarding energy efficiency with 

respect to the revised or successor code. 

B. Public Hearing and Initial Comments on Methodology 

In arriving at a determination, the Department first reviewed all significant changes 

between the 1989 edition and the 1999 edition of Standard 90.1. Standard 90.1 is complex and 

covers a broad spectrum of the energy related components and systems in buildings ranging from 

simple storage buildings to complex hospitals and laboratories. The size of buildings addressed 

range from those smaller than single family homes to the largest buildings in the world. The 

approach to development of the standard changed from that used for the 1989 edition, as did the 

scope and the way components were defined. We concluded that a simple comparison of the two 

editions would not be possible. Therefore, we decided to hold a public workshop and seek public 

comment on our proposed analysis methodology. On February 8, 2000, we proposed a 

methodology, announced a public workshop, and sought public comment, 65 FR 6195 et seq. On 

February 17,2000, we held a workshop to obtain comment on the approach we proposed to use. 

See the summary of the proposed approach in Appendix A of the final determination. 

We requested comments andlor data concerning issues relating to the comparative 

analysis of Standard 90.1-1989 and Standard 90.1-1999 (the 1989 and 1999 editions). We 

especially expressed interest in any coiments or data regarding: I) the seven building types 

selected for analysis; 2) the 11 representative climate locations proposed for the analysis; 3) the 

frequency of use of alternative paths to compliance in building standards (e.g., space-by-space 

versus whole building lighting power allowances); 4) new nonresidential building construction 

data, by state or census division and building type; 5) data to quantify the impact of the 1999 

edition on additions and renovations to existing buildings; 6) the prevalence of the semi-heated 

building envelope subcategory in the building types proposed for analysis; and 7) specific 

comments on the preliminary energy savings analysis were distributed in June 1999. 

We received a number of comments, reviewed them, and adjusted the methodology 

 6450-01-P COMMENT 18
appropriately, before completing the analysis. A response to these comments is contained in the 

final determination, not in this document. 

C. Comments on Preliminary Quantitative and Textual Analyses 

As a matter of policy to further the determination process, we sought further comments on 

the application of the methodology and the validity of preliminary conclusions posted on our web 

site at: . An email invitation was sent to the members of Standing Standards Project Committee 90. l, the 

committee that developed the standard, and to those who had previously commented on our 

proposed methodology. (See Appendix A.) The invitation to comment was also extended 

verbally at the January 2001 winter meeting of SSPC 90.1. The invitation was further extended 

to States by the Department's Regional Offices. An invitation to comment was also posted on the 

above web site and a page for posting comments was created. (See Appendix B). 

We received 12 comments. Some were submitted through the web site response page, 

some were received by e-mail, and still others were submitted by mail. While a deadline for 

comments was established in the invitation, several comments were received after that date, but 

were considered in completing the determination. 

This document contains these comments and the Department's response to them. 

D. Numbering and Identification of Comments and Responses. 

Each comment was assigned a number in the order received. Each paragraph of each 

comment was in turn assigned a decimal suffix to the comment number, such that the first 

paragraph of the first comment was numbered 1.1. These numbers are used in the response to 

comments to indicate how comments were aggregated and responded to in the final 

determination. 

Each person commenting is identified by name and their affiliation is noted. A subject for 

each comment has been assigned for easy reference. The subject assigned is not intended to 

encompass all aspects of each comment. 

Numbering included within a comment has been retained for easy identification by their 

authors. 

11. Comments and Responses. 

The following are the comments received regarding the Department's preliminary 

analyses supporting the determination, and the Department's responses to thosse comments. 

1. Comments by Gersil Kay, Conservatio~l Lighting International 

1.1. Future Standard. 

As a member of the lighting subcommittee, I feel strongly that, in addition to wattage 

restrictions and lighting controls, lighting systems more energy-efficient than the conventional 

incandescent, halogen and fluorescent lamps specifically mentioned in the Standard, should also 

be made part of the criteria. This is because even if ingenious occupants get around the wattage 

restrictions and lighting controls, if products that use less energy to begin with are employed, 

there will still be conservation. 

 6450-01-P COMMENT 18
Response: This is not a comment on the draft analysis or determination. The comment 

expresses an opinion on the nature of a future standard. No change has been made to the 

draft analysis in response to this comment. 

1.2. Luminaire 

As a second-generation commercial electrical contractor, which was the second oldest 

finn in Philadelphia, I also am concerned that the arbitrary terminology of "luminaire" as defined 

in the Standard, is confusing and may impair energy conservation. This term neither promotes 

metric use nor indicates international usage. The British Department of the Environment, 

counterpart to the U. S. Department of Energy, always modifies the word lurninaire with (lighting 

fitting). I lecture regularly in Great Britain. In the USA, it has been called a lighting fixture for 

100 years. 

Response: This is not a comment on the draft analysis or determination. This comment 

expresses an opinion as to the terminology that should be used in Standard 90.1. No 

change has been made to the draft analysis in response to this comment. 

1.3. Efficient lighting systems. 

Lighting systems based on total internal reflection, such as light pipe and glass fibre optics 

functional architectural lighting, as opposed to individual lighting fixtures, are very energyefficient. They have been used abroad for decades. If inention of such equipment is not included 

in the Standard, younger or more inexperienced practitioners not familiar with this completely 

different technology, will not use them to comply with the Standard's or code's parameters. 

Response: This is not a comment on the draft analysis or determination. The comment 

expresses an opinion that light pipes and fiber optics should be mentioned in Standard 

90.1. No change has been made to the draft analysis in response to this comment. 

1.4. Book on fibre optics. 

Because of the lack of training in these systems, I wrote the first comprehensive book on 

the subject. Fibre Optics in Architectural Lighting (McGraw-Hill, 1999) is sold worldwide as a 

textbook and industry reference. It is in its third printing. 

Response: This is not a comment on the draft analysis or determination. The comment 

provides information about the person commenting having written a book. No change has 

been made to the draft analysis in response to this comment. 

1.5. Americans behind in lighting. 

Our foreign colleagues say Americans are ten years behind in lighting. Isn't it time we 

catch up? 

 6450-01-P COMMENT 18
Response: This is not a comment on the analysis or determination. No change has been 

made to the draft analysis in response to this cormnent. 

2. Comments by S. Gregg Johnson, Johnson, Spellman & Associates 

2.1. Delay in making determination. 

Thank you for your update on the 90.1 review forwarded to me from Tracy Leath. I have 

been pressing Tracy on a decision on this issue for several months. 

Frankly, I am at a loss to understand why it is taking so long to adopt this Standard when 

there is really no other comprehensive substitute available. 

Response: This is not a comment on the analysis. The comment expresses concern about 

the amount of time it is taking DOE to make its determination. It is not relevant that, " . . . 

there is really no other comprehensive substitute available." Aggregate with comment 2.1 

(sentence 3), 4, 5.1, 8.4, and 10.8, and report the concern about the delay. No change has 

been made to the draft analysis in response to this comment. 

2.2. State hesitation to adopt the 1999 edition. 

Georgia, as well as a number of other states, is in the process of planning an update to 

the current state energy code, which uses 90.1, 1989 as the base document. However, Georgia 

hesitates to adopt the new 90.1 Standard until DOE provides it's blessing. DOE needs to quickly 

adopt 90.1, 1999 as an encouragement to individual states to follow suit. 

Response: This is not a comment on the draft analysis. This comment expresses the need 

for a prompt determination as an encouragement to individual states to update their 

energy codes and comments on the impact of the delay on GA and other states. We 

aggregated this comment with comments 2.2, 4, 5.1, 6.2, 8.2, 8.3 and 9.5 on the impact on 

states. No change has been made to the draft analysis in response to this comment. 

2.3. Impact of delay compounded. 

The impact of this DOE decision delay is compounded by the recent energy problems in 

California and cost increases for fuels across the country. 

Something needs to be done NOW. 

I am thinking about contacting our entire congressional delegation regarding this issue, 

but I will wait for your response first. 

Response: This is not a comment on the analysis. We aggregated this comment with 

comment 2.1 above. No change has been made to the draft analysis in response to this 

comment. 

3. Left blank for consistency with internal working documents. 

4. Comments by Stuart Cowen, Building Code Commission, State of Rhode Island 

 6450-01-P COMMENT 18
4.1. Delay in making a determination. 

A positive determination by DOE will inform the state of Rhode Island efforts to develop 

and adopt an updated commercial building energy code based on their International Energy 

conservation Code 2001 Edition. DOE's failure to meet the deadline for a determination, as 

specified in the Energy Policy Act of1992, is inhibiting the development, adoption and 

implementation of an updated commercial building energy code in the state of R I. We urge DOE 

to issue immediately a positive determination. The state of RI hopes to implement the Energy 

code this current legislative session. 

Issuance of a timely positive determination will greatly facilitate the ability of the state of 

RI to move forward in updating and implementing improved building energy codes and to secure 

major potential gains in energy and greenhouse gas reductions in the commercial building sector. 

Response: This is not a comment on the analysis. We aggregated this coinment with 

comment 2,2.1,4, 5.1, 8.4 and 1 0.8 on concern about delay and reflected it in the 

background section of the determination. No change has been made to the draft analysis 

in response to this comment. 

We aggregated this comment with comment 2.1, 2.2,4, 5.1, 6.2, 8.2, 8.3, and 9.5 on 

impact of delay and reflected it in the background section of the determination. No 

change has been made to the draft analysis 

We aggregated this comment with comment 4, 5, 5.2, 6.1, 6.2, 8,8.2, 8.4, 9.5 on urging 

prompt positive determination. We included it in the background section of the 

determination to reflect this opinion with a counter point in comment 12. 

5. Comments by Susan Coakley, Northeast Energy Efficiency Partnerships, Inc. 

5.1. Analysis reasonable and assessment correct. 

This letter is in response to your request for comments on the US Department of Energy's 

(DOE) analysis of the Detailed Textural Analysis of the estimated differences between the 1989 

and 1999 editions of ASHRAE/IESNA Standard 90.1. Northeast Energy Efficiency Partnership, 

Inc. (NEEP) has reviewed DOE's application of methodology and the validity of its preliminary 

conclusions. NEEP finds that the analysis conducted by DOE is reasonable. Furthermore, NEEP 

concurs with your assessment that the 1999 edition of Standard 90.1 will produce a net positive 

increase in the energy efficiency of new, altered and renovated commercial buildings. 

Response: We aggregated this comment with comment 5 and 9.3 concluding that the 

analysis is reasonable. We include it in the background section of the determination to 

reflect this opinion with a counter point in comment 1 1.1 all, 12.1, 12.3, 12.4, 12.5, 12.7, 

and 12.8. 

 6450-01-P COMMENT 18
We aggregated this comment with 5, 8,9.3, 10.2, 10.3, and 13 agreeing about a net 

positive impact. We included it in the background section of the determination to reflect 

this opinion with a counter point in comment 12.7. 

We aggregated this comment with 8.3,9.4, and 10.3 regarding increase energy efficiency 

due in part to inclusion of existing buildings in 1999 edition. We include it in the 

background section of the determination to reflect this opinion with counter points in 1 I. 1 

and 11.5. 

5.2. Delay in making a determination. 

A positive determination by DOE is an essential step to inform the efforts of states in the 

Northeast region to develop and adopt an updated colnmercial building energy code based on the 

International Energy Conservation Code 2001 Edition, which references ASHRAEAESNA 

Standard 90.1-1 999 in Chapter 7. 

DOE'S failure to meet the deadline for a determination, as specified in the Energy Policy 

Act of 1992, is inhibiting the development, adoption and implementation of an updated 

commercial building energy code in several Northeast states. NEEP urges the Department of 

Energy to issue immediately a positive determination. 

Issuance of a timely positive determination will greatly facilitate the ability of states in the 

Northeast region to move forward in updating and implementing improved building energy codes 

and to secure major potential gains in energy and greenhouse gas reductions in the commercial 

building sector. We urge your immediate action on a positive determination. 

Response: This is not a comment on the analysis. We aggregated this comment with 

comments 2.1,2.2,4, 6.2, 8.2, 8.3, and 9.5 on the impact of the delay and reflected it in 

the background section of the determination. No change has been made to the draft 

analysis in response to this comment. 

We aggregated this comment with 2, 2.1, 4, 5, 6.1, 6.2, 8, 8.2, 8.4, and 9.5 urging a 

prompt positive determination. We include it in the background section of the 

determination to reflect this opinion with counter point 12. 

6. Comments by Randall Lloyd, Vermont Department of Public Service 

6.1. Introductory statement. 

These comments are offered in response to your request for comments on the US 

Department of Energy's analysis of the Detailed Textural Analysis of the estimated differences 

between the 1989 and 1999 editions of ASHRAE/IESNA Standard 90.1. 

Response: This is not a comment on the analysis. No response is needed. 

6.2. Agreement with assessment. 

 6450-01-P COMMENT 18
The State of Vermont, Department of Public Service supports your assessment that the 

1999 edition of Standard 90.1 will produce a positive increase in the energy efficiency of new, 

altered and renovated commercial buildings. 

Response: We aggregated this comment with 8, 9.3, 10.2, 10.3, and 13 agreeing about a 

net positive impact. We include it in the background section of the determination to 

reflect this opinion with counter point 12.7. 

6.3. Request immediate action. 

We in Vermont, and a number of our neighboring states, are in the process of 

implementing new IECC 200 IIASHRAE 90.1 - 1999 coinmercial building energy codes and 

believe that a positive detennination by DOE will advance our energy code implementation 

efforts. 

I have copied the text of a letter of August 15,2000 from Richard Sedano to Dan Reicher 

on this matter, below. We continue to believe that a timely determination will greatly facilitate 

our ability to move forward with the adoption and implementation of iinproved commercial 

building energy standards. We urge your immediate action on a positive determination and thank 

you for the opportunity to submit these comments. 

Text of previous letter follows . 

August 1 5,2000 

Mr. Dan Reicher, Assistant Secretary 

Office of Energy Efficiency and Renewable Energy 

US Department of Energy 

1000 Independence Avenue, S W 

Washington, DC 20585-012 1 

RE: Determinations Pursuant to Title 42, Chapter 8 1, Subchapter 11, Section 6833. 

Updating state building energy efficiency codes 

Dear Mr. Reicher: 

This letter is in response to the release of new editions of national model building energy 

codes and standards. 

The State of Vermont Department of Public Service encourages you to make positive 

determinations on the 2000 International Energy Conservation Code and 

ASHRAEIIESNA Standard 90.1-99. We ask for an expedited completion of the 

Department of Energy's requirements under the Energy Policy Act of 1992 regarding 

these model codes and standards. They represent major potential gains in energy savings 

and greenhouse gas reductions in the residential and commercial building sectors. To 

accelerate Vermont's residential and commercial energy codes adoption processes, DOE'S 

 6450-01-P COMMENT 18
determinations are a critical policy step, and we urge you to issue them in this calendar 

year. 

In February 1999, the International Energy Conservation Code (IECC), 1998 edition, 

succeeded the CAB0 Model Energy Code. Substantial improvements to the energy 

efficiency provisions were included in this revision. The IECC was again modified in 

1999 and published in March 2000. Further improvements were made to the IECC 2000 

including a simplified compliance path for residential buildings that simplifies the 

compliance process. 

In February 2000, the ASHRAEIIESNA Standard 90.1-99 (Standard 90.1-99) succeeded 

the ASHRAEIIES Standard 90.1-1 989. This spring, the IECC Committee approved 

referencing the revised ASHRAE Standard in the 2001 Supplement to the IECC 2000. 

They also approved a number of changes that make the text in Chapter 8, Design by 

Acceptable Practice, that bring the energy efficiency of that Chapter near Standard 90.1 - 

99 levels. 

These changes represent a substantial improvement in the energy efficiency of minimum 

codes and standards in the United States. For the State of Vermont to benefit from these 

changes, these model codes and standards must be incorporated into state and local codes; 

building officials, builders and designers in Vermont must be trained and have access to 

support materials, and the codes must be enforced. Only then will these changes begin to 

benefit Vermont consumers and the environment. The U.S. Department of Energy's 

determinations will greatly facilitate Department of Public Service advocacy before the 

Vermont Department of Labor and Industry, which has indicated a strong preference for a 

positive U.S. DOE determination when considering rulemaking to adopt updated energy 

codes. 

The U.S. Department of Energy has played a major role in improving the use of national 

model codes and standards. Compliance tools, technical support and direct funding to the 

State of Vermollt by the Department have been instrumental to the success of Vermont's 

energy code activities. This success has created an environment that supports energy code 

upgrades at the state level. However, timely determinations are needed in order to 

facilitate progressive upgrades of Vermont's existing residential and proposed comercial 

energy codes with the most current national model energy codes. 

The IECC 2000 and Standard 90.1-99 are superior to their successor codes and standards 

and immediate action should be taken to issue the Secretary's determinations. The State of 

Vermont encourages you to request that the Secretary issue such determinations. 

Thank you in advance for your assistance. 

Sincerely, 

 6450-01-P COMMENT 18
Richard P. Sedano 

Cominissioner 

cc: Mark Ginsberg, U.S DOE-HQ 

Gail McKinley, U.S. DOE-HQ 

Jean Boulin, U.S. DOE-HQ 

Christine Rheinfelds, U.S. DOE-Boston 

Response: We aggregated this comment with cormnent 4, 5, 5.2, 6.1, 6.2, 8, 8.2, 8.4 and 

9.5 on urging prompt positive determination. We included it in the background section of 

the determination to reflect this opinion with a counter point in comment 12. 

We aggregated the response to the letter with the rest of the comment. 

7. Comments by John Hogan, Seattle Dept. of Design, Construction, and Land Use 

7.1. Envelope criteria for "10dging.'~ 

These comments apply to the QUANTITATIVE analysis for ASHRAE/IESNA Standard 

90.1. 

The building envelope criteria for the "lodging" category should be taken from the 

"residential" column in the tables in Appendix B (rather than from the "nonresidential" category). 

Response: We agree. We have corrected input errors with the relevant envelope 

parameters in the 1999 edition's residential building category, rerun the 

quantitative analysis and included the results in the determination. Note 

that the correction increases the 1999 edition's energy savings. 

7.2. Elevators. 

The analysis should be expanded to include all the energy use in the buildings: add 

elevators. For elevator schedules, use the values from the U.S. Department of Energy Standard 

Evaluation Technique. For quick reference, these values are included in the Washington State 

Energy Code in Reference Standard (RS) 29, Tables 3-2A to 3-25, available on the Seattle Energy 

Code website at: 

Response: We disagree. Data about the number of buildings that have elevators and 

about the characteristics of those elevators is not available in data bases that we are aware 

of. 

Energy use for elevators is not addressed in either the 1989 or the 1999 edition. 

Therefore, elevators would have no impact on the determination regarding the 

improvement of energy efficiency in commercial buildings. 

 6450-01-P COMMENT 18
Adding energy use for elevators would increase the base electrical load for some 

buildings. This would reduce the percent energy savings, but cause no change in absolute 

energy savings. 

Adding elevators might also increase building cooling loads. Because cooling equipment 

efficiency is increased in the 1999 edition, it is expected that this would slightly increase 

the cooling energy savings for the 1999 edition. However, the amount of the increase will 

depend heavily on assumptions about the number of elevators in buildings. We made no 

change to the draft analysis. 

7.3. Exterior lighting. 

The analysis should be expanded to include all the energy use in the buildings: add 

exterior lighting (specifically: entrances, exits, and facades). 

Assume that lighting operates 12 hoursiday year round. 

- For the 1989 version: use values from Table 6-1 per Section 6.4.1.1. 

- For the 1999 version: use values from Table 9.3.2 per Section 9.3.2. 

Response: Energy use for exterior lighting was not individually examined in the 

quantitative analysis, but is included in the whole building requirements used in the 

analysis. (See the rational in the proposed methodology for using whole building lighting 

criteria rather than space-by-space analysis.) 

Our review of the requirements of these two editions suggests that the 1999 edition's 

exterior lighting requirements are equivalent to, or more stringent than the 1989 edition's, 

in most instances for lighting of building exits and entrances, and for building facades in 

some cases. Hence, addition of exterior lighting power to the quantitative analysis would 

increase the absolute savings shown for the 1999 edition and would add more support for 

a positive determination of energy savings with the 1999 edition. We made no change to 

the draft analysis. 

7.4. Parking lighting. 

The analysis should be expanded to include all the energy use in the buildings: add 

parking lighting. 

Assume that lighting operates 24 hourslday year round. 

- For the 1989 version: for surface parking use values from Table 6-1 per Section 6.4.1.1, 

for parking garages use values from Table 6-5 per Section 6.5.4. 

- For the 1999 version: use values from Table 9.3.1.1 per Section 9.3.1.1. 

Response: Energy use for exterior lighting was not individually examined in the 

quantitative analysis, but is included in the whole building requirements used in the 

analysis. (See the rational in the proposed methodology for using whole building lighting 

criteria rather than space-by-space analysis.) 

 6450-01-P COMMENT 18
For building grounds, driveways, walkways, parking lots and loading areas, the1989 

edition has lighting requirements in terms of allowable watts per square foot. The 1999 

edition replaces these with a requirement that all lighting in these areas have a minimum 

efficacy of 60 lumens per Watt. We have no way to reasonably compare these 

requirements. However, we believe that there is some potential for the total lighting 

power to these areas to increase due to the change in requirements in the 1999 edition. We 

made no change to the draft analysis in response to this comment. 

Regarding the suggestion to use a 24-hour schedule for parking lot lighting, the 1989 

edition has a requirement that, if the exterior lighting is not intended for 24-hour 

operation, it shall be controlled by timer or photocell or combination thereof. Similar 

language exists in the 1999 edition, with an exemption for lights at covered entrances or 

exits for vehicles. We believe that an assumption of 24-hour operation is inappropriate. 

Perhaps an operating period of 12 hours would be more appropriate for a yearly average. 

However, we do not believe that one can reasonably define the illuminated area and 

measure Watts per square foot in the 1989 edition when calculating exterior lighting. We 

made no change to the draft analysis in response to this comment. 

7.5. Parking ventilation. 

The analysis should be expanded to include all the energy use in the buildings: add 

parking ventilation. 

Assume ventilation at 1.5 cfmlsf per Building Code. 

- For the 1989 version: assume no automatic shutoff. 

- For the 1999 version: assume automatic shutoff control for systems over 30,000 cfm per 

Section 6.2.3.5. 

Response: Data on the amount of parking in buildings and about the characteristics of 

that parking is not available in any data bases that we are aware of. Further, the proposed 

nlethodology to simulate parking ventilation is incomplete, in that it does not address the 

total area of parking garages. Nor does the methodology provide typical operating hours 

for garages or fan pressure requirements. The suggested inclusion of shutoff controls 

would enhance the absolute energy savings under the 1999 edition. We made no change 

to the draft analysis in response to this comment. 

7.6. Fans and part load operation. 

The analysis should be expanded to differentiate part load operation between fan systems 

with and without variable frequency drive. 

- For the 1989 version: use values from Section 9.5.4.3.2. 

- For the 1999 version: use values from Section 6.3.3.2.1. (Note that both threshold and 

allowed wattage change.) 

Response: Data on the number and distribution of various fan systems in buildings is not 

available in any data bases that we are aware of. Therefore, we cannot reliably model this 

impact. We made no change to the draft analysis in response to this comment. 

 6450-01-P COMMENT 18
We do know that the requirements for variable frequency drive performance are more 

stringent in 1999 edition than in 1989 edition. Fan systems with variable frequency drive 

would therefore increase the absolute energy savings under the requirements of the 1999 

edition. 

8. Comments by David Weitz, Massachusetts Board of Building Regulations and 

Standards 

8.1. Conclusions reasonable. 

I have reviewed the Detailed Textual Analysis, and believe that its conclusions about net 

positive increase in energy efficiency owing to adoption of ASHRAE Standard 90.1-1999 is 

reasonable. 

Response: We aggregated this comment with 5, 9.3, 10.2, 10.3, and 13 agreeing about a 

net positive impact. We included it in the background section of the determination to 

reflect this opinion with counter point 12.7. 

8.2. Achievable standard. 

Furthermore, this is an achievable standard; the very fact that it was vetted through the 

ANSI process indicates that all parties can live with. 

Response: This is not a comment on the analyses. The comment is not relevant to the 

determination. We cCombined it with the response to AGA comment on the 

determination process in earlier comments on the proposed analysis methodology . We 

combined it with comment 9 and included it in the background of the determination to 

reflect this opinion with a counterpoint in comment 12.2. 

8.3. Encourage timely, positive determination. 

Although the Commonwealth of Massachusetts has already adopted a new construction 

energy code based on the stringencies of Standard 90.1-1999, we still encourage DOE to make a 

positive determination, and to do so in a timely manner. The design and construction of 

"commercial" buildings is a regional (indeed, a national) process, with architects, engineers, and 

construction companies working across state boundaries. The degree to which the states in our 

region, and throughout the nation, share similar requirements will make it easier on all parties to 

produce energy efficient buildings. 

Response: This is not a comment on the draft analysis. The comment urges a prompt 

positive determination. We aggregated this comment with comment 4, 5, 5.2, 6.1, 6.2, 8, 

8.2, 8.4 and 9.5 on urging a prompt positive determination. We included it in the 

background section of the determination to reflect this opinion with a counter point in 

comment 1 2. 

8.4. Standard covers existing buildings. 

 6450-01-P COMMENT 18
Another important value of the Standard is that it covers existing buildings. As the 

Textual Analysis suggests, the impact of the ASHRAE Standard on existing buildings will be 

significant. Massachusetts is the midst of updating its energy conservation provisions for existing 

buildings, and guidance from the Standard will be helpful in both our work's content and the ease 

of its adoption within the Commonwealth 

Response: We aggregated this comment with 8.3, 9.4, and I 0.3 regarding increase 

energy efficiency due in part to inclusion of existing buildings in the 1999 edition. We 

include it in the background section of the determination to reflect this opinion with 

counter points in comments 1 1.1 and 1 1.5. 

8.5. Support positive determination, concerned about delay. 

For all these reasons, I strongly support a positive determination by DOE as quickly as 

possible. This process has unfortunately lingered for too long, with expectations being repeatedly 

disappointed. The time has finally come to act on this important matter. 

Response: We combined this comment with comment 8.2 and included it in the 

background section of the determination to reflect this opinion. 

9. Comments by James E. Wolf, President of the American Society of Heating 

Refrigerating and Air-Conditioning Engineers (ASHRAE) and Martyn Timmings, 

President of the Illuminating Engineering Society of North America (IESNA) 

9.1. Support Standard 90.1 process. 

We are writing in response to your request for comments regarding the application of the 

DOE methodology for the analysis of the energy savings of ANSIIASHRAEIIESNA Standard 

90.1 - 1999 compared to those of Standard 90.1 - 1989, and the validity of DOE'S preliminary 

conclusions. As joint developers of Standard 90.1-1999 we stand behind its objectivity and the 

openness, balance, and due process of the American National Standards Institute (ANSI) 

consensus process under which it was approved. With the standard under continuous 

maintenance, ASHRAE will republish an improved, updated version in 2001 and every three 

years thereafter. 

Response: This is not a substantive comment on the draft analysis. We aggregated this 

comment with comment 8.1. We included it in the background section of the 

determination with the response to an AGA comment on process in the earlier comments 

on the analysis methodology. 

9.2. PNNL Analysis. 

Pursuant to the 1992 Energy Policy Act, DOE must determine whether Standard 90.1 - 

1999 would improve energy efficiency in commercial buildings compared to the 90.1-1989 

version it replaces. To guide this determination, DOE, through the Pacific Northwest National 

Laboratory (PNNL), conducted an analysis of the likely impacts of the revised standard on the 

 6450-01-P COMMENT 18
energy efficiency of new buildings in seven commercial building categories, compared to the 

1989 version. That analysis concluded that the 1999 revision of the standard would reduce 

source energy consumption by 5.9% and site energy consumption by 3.9%. 

Response: This is not a substantive comment on the draft analysis. We combined it with 

comment1 0.2 regarding determination requirements. We include it in the background 

section of the determination to reflect this opinion with counterpoint 12. 

9.3. Analysis well done, conservative and supports positive determination. 

We are satisfied that the PNNL analysis was thorough and used a reliable building energy 

analysis computer program. Carefully constructed prototypes were analyzed for seven building 

types that accurately represent the energy use patterns of the vast majority of new buildings in the 

U.S. We believe competent building energy analysts conducted the analysis after their approach 

and methodology were subjected to open and thorough public review and criticism. However, we 

believe the source and site energy savings estimates to be conservative because the assumptions 

made in the modeling are conservative. Nonetheless, we believe the conclusions drawn are 

adequately accurate to demonstrate that Standard 90.1 - 1999 unquestionably will improve the 

energy efficiency of commercial buildings relative to 90.1 - 1989. 

Response: We aggregated this comment with 5, 9.3 concluding analysis is reasonable. 

We reflected it in the background section of the determination with a counter point in 

comments 11.1 all, 12.1, 12.3, 12.4, 12.5, 12.7, and 12.8. 

We aggregated this comment with comments 5, 8,9.3, 10.2, 10.3, and 13 agreeing about a 

net positive impact. We included it in the background section of the determination to 

reflect this opinion with a counter point in comment 12.7. 

9.4. Existing buildings impact. 

It also should be noted that because Standard 90.1- 1999 applies to renovations and 

retrofits to existing buildings, which are not covered in 90.1-1989, even more energy savings will 

result than are estimated by the PNNL analysis. lndustry estimates indicate that at least 60% of 

heating and cooling equipment sales are for replacement markets, and only 40% for new 

buildings. Furthermore, the 1999 version is less complex, and thus there should be more 

incentive to adopt it to replace the 1975 or 1980 versions, or where no codes or standards have 

yet been adopted. While those savings are not reflected in the PNNL analysis, the fact is they are 

real. 

Response: We aggregated this comment with 8.3, 9.4, and 10.3 regarding increase 

energy efficiency due in part to inclusion of existing buildings in 1999 edition. We 

included it in the background section of the determination to reflect this opinion with 

counter points in comments 1 I. 1 and 1 1.5. 

9.5. Endorse results of analysis. 

 6450-01-P COMMENT 18
Consequently we strongly endorse the results of this analysis as the basis for the 

determination that Standard 90.1 - 1999 be the new reference standard for state commercial 

building codes. We urge the DOE to complete its determination quickly so that the additional 

savings may accrue as soon as possible. 

Response: The first sentence is relevant, see comment 9.4. The second sentence does 

not address the draft analysis. We aggregated the first sentence with comment 9.4 and 

reflected it in the background section of the determination. 

We aggregated this comment with comments 4, 5, 5.2, 6.1, 6.2, 8, 8.2, 8.4 and 9.5 on 

urging prompt positive determination. We included it in the background section of the 

determination to reflect this opinion with counter point 12. 

10. Comments by David Goldstein, Natural Resources Defense Council 

10.1. Introduction. 

The Natural Resources Defense Council (NRDC) is an environmental organization with 

more than 400,000 members nationwide. NRDC has been participating in energy efficiency 

standards proceedings for non-residential buildings since the mid-1970's and participated actively 

in the development of ASHRAE standards 90.1-1989 and 90.1-1999. 

Response: This is background information and does not comment on the draft analysis. 

No response is required. 

10.2. Adequacy of standard and standards process. 

The Department of Energy is required, under Section 304 of the Energy Conservation and 

Production Act (ECPA) to "determine whether [a] revision [of ASHRAE 90.1-19891 will 

improve energy efficiency in commercial buildings." NRDC has many grave reservations about 

the adequacy of ASHRAE 90.1-1999 to serve as a basis for national or state energy policy. We 

objected to the process by which ASHRAE made its final decisions, and we believe that the 

content of the standard fails to achieve the improvements in energy efficiency that ASHRAE's 

own policies, much less its responsibility as a non-profit organization to support the public 

interest, would demand. 

Response: This does not comment on either the draft analysis or the subject of the 

determination (will the 1999 edition improve the energy efficiency of commercial 

buildings). No response is required. 

10.3. Analysis conclusion correct. 

Nevertheless, the requirements under the law are for the Secretary of Energy simply to 

determine whether the revised standard improves energy efficiency in commercial buildings 

compared to the 1989 standard. NRDC believes that DOE'S tentative conclusion that it does so is 

correct. 

 6450-01-P COMMENT 18
Response: We aggregated the first sentence of this comment with 10.3 as counterpoint to 

comment 12.1 regarding determination requirements. We include it in the background 

section of the determination to reflect this opinion with counter point 12.1. 

We aggregated this comment with comment 5, 8, 9.3, 10.2, 10.3, and 13 agreeing about a 

net positive impact. We include it in the background section of the determination to 

reflect this opinion with counter point 12.7. 

10.4. Significant improvements. 

The new standards make significant improvements in the efficiency of lighting systems in 

most occupancies and in most circumstances. In addition, the HVAC equipment efficiency 

requirements are higher. Also, the scope of the standard is broader such that it covers remodels 

and "tenant improvements" as well as new construction. 

Response: We aggregated this comment with co~ments 5, and 8 (general). We include it 

in the background section of the determination to reflect this opinion. 

We aggregated this comment with comments 5, 8, 9.3, 10.2, 10.3, 10.4, 10.6 and 13 

agreeing about a net positive impact. We included it in the background section of the 

determination to reflect this opinion with the counter point in comment 12.7. 

10.5. Alternative analysis. 

These observations are consistent with DOE'S analysis showing only slight (about 5%) 

improvements in energy efficiency due to the standard. Alternative analyses show even weaker 

savings. 

Response: We aggregated this comment with comments 10.3 above and 10.6 below. 

We aggregated this comment with comment 12.7 regarding weaker 

savings. 

10.6. Significant improvements to Standard 90.1 possible. 

ASHRAE should be embarrassed to be promoting such minimal improvements in energy 

efficiency from a base that already wasn't very stringent. NRDC succeeded in making our own 

building use one-third the energy of ASHRAE 90.1 in the late 80's, using only cost-effective 

measures that maintained or improved comfort and productivity. This is distressingly slow 

progress. It is all the more disturbing in the face of significant improvements in the efficiency of 

components and subsystems of non residential buildings, including much wider availability of T8 and electronic ballasts, new T-5 lamps, new availability of dimmable compact fluorescent lamps 

and smaller compact fluorescent lamps, the development of better guidance on the use of 

daylighting to replace electric lighting, the vast improvement in chillers, the much wider 

 6450-01-P COMMENT 18
availability of varied and lower cost, variable speed drives, and widespread experience with more 

energy conserving designs using existing equipment. 

Response: This does not comment on the draft analyses or the determination. No 

response is required. 

10.7. Small positive improvement. 

So, from a strict legal point of view, while a 5% improvement may be embarrassingly 

small, it is nonetheless an improvement. 

Response: We aggregated this comment with comment 10.3 and 10.4. 

10.8. DOE should advocate further improvements. 

NRDC also believes there is a public benefit in DOE'S certifying the new standard. 

According to EPCA, an affirmative determination by the Secretary will require states to review 

and update their own commercial energy codes. NRDC believes that this process provides an 

opportunity for DOE to advocate further upgrades in state energy codes beyond the minimum 

requirement in the law of meeting or exceeding the requirements of ASHRAE 90.1-1999. 

Response: This does not comment on the draft analyses or the subject of the 

determination. No response is required. 

10.9. Federal standards. 

Section 305, in particular, requires DOE to compare standards for federal buildings-- 

which must include all "those energy efficiency measures that are technologically feasible and 

economically justifiedw--to the ASHRAE standard. DOE should promptly complete this analysis 

and issue a federal standard that meets the statutory criteria. Following such issuance, DOE will 

be in a position to advocate state adoption of the federal standard in place of the ASHRAE 

standard. NRDC believes that by certifying the ASHRAE standard, DOE is taking a first step 

that can lead to this much more productive process. 

Response: This does not comment on the draft analyses or on the subject of the 

determination. Section 305, addresses the Federal energy efficiency code. This is not 

relevant to this determination. No response is required. 

11. Comments by Robert Hemphill, Gas Technology Institute' 

The numbering in the text of the following comments was assigned by the author and refers to the numbering in the 

Department's draft textual analysis. 

 6450-01-P COMMENT 18
11.1. Introduction and background. 

The attached document file entitled Critique of DOE Commercial Buildings 

Determinations (Word 2000, SR-1 format) presents the Gas Technology Institute's coinments and 

critique of the following DOE documents: 

I) Commercial Buildings Determinations? Explanation of the Analysis and Spreadsheet 

(usually referred to as the Quantitative Analysis) 

2) Detailed Textual Analysis of the Differences Between the 1989 and 1999 Editions of 

Standard 90. I? Energy Standard for Buildings (usually referred to as the Qualitative Analysis). 

Background. The sixth paragraph of this section states "if the value of annual investment 

in building alterations and renovations is a good indicator of their impact on energy use, then the 

expansion of the code to existing buildings could produce 50 percent more savings than if it were 

applied to new buildings alone." The implication of this statement is that the scope of the 1989 

standard does not include existing buildings. However, this conclusion runs counter to 

documented ASHRAE interpretations. A Memorandum from SSPC 90.1 to Standards Committee, 

dated June 25, 1995, makes the following observation: 

Our proposed language is merely a clarzfication of the language in the original 

Title, Purpose and Scope (TPS). Item 2.2 in the original TPS said the Standard 

applied to "all new buildings or portions of buildings. " It is the considered 

opinion of the engineeu, building oficials, lighting designers and architects on 

the SSPC that this means "all new bzcildings or new portions of buildings." 

Virtually all building codes apply to any new construction, whether it is an 

entirely new building, an addition to a building, or to new remodeling work. There 

are no new codes that apply solely to buildings that are new out of the grozind. We 

have written the Code with this reality in mind We have not includedprovisions 

where new work would trigger requirements to upgrade existing building 

components that are not otherwise being worked on. The Code only applies to the 

new work. Our TPS does not extend the scope of the existing TPS, it merely 

clarzjies the description of how it applies. 

The last paragraph of this section states unequivocally "together, these analyses appear to 

indicate that the revised code will improve the energy efficiency of commercial buildings." Given 

the differing provisions of the two standards, the only way to accurately interpret the impact of 

the requirement is to set the text side-by-side and allow the reader to reach hidher own 

conclusions. The entire premise of this analysis is suspect because the relative weighting of the 

impacts discussed are not known. There are numerous instances throughout this document in 

which the conclusions drawn appear biased toward the existence of energy savings. For example, 

when energy savings appear likely under the 1999 standard, this conclusion is strongly asserted. 

However, where energy savings appear to be unlikely, the conclusion is generally that there is 

insufficient data. In addition, energy reduction credits already taken in the quantitative analysis 

should be clearly identified to avoid double counting. 

Response: See comment 11.5 regarding the scope (existing buildings). Also, see 

comment 12. 

 6450-01-P COMMENT 18
We believe we have clearly identified where the 1999 edition will be less stringent or only 

modestly beneficial. 

We have a responsibility to make a determination whether the 1999 edition will improve 

the energy efficiency of commercial buildings and, "[setting] the text side-by-side and 

[allowing] the reader to reach hislher own conclusions," is not an option. 

By definition, the textual analysis puts no numeric value on the subject and therefore does 

not double count. 

We have made no change to the draft determination in response to this comment. 

11.2. Scope - Existing buildings. 

I. Summary of the Comparative Analysis; A. Quantitative Analysis (Note: Additional 

comments regarding the Quantitative Analysis appear on pages 1 through 5 of this docztment.) 

Paragraph two of this section concludes that the inclusion of additions and renovations to existing 

buildings in the scope of the 1999 standard will have a significant (albeit unquantifiable) energy 

impact. It has previously been shown (refer to previous comments under Background) that there 

is no change in scope between the 1989 and 1999 standards regarding existing buildings. 

Therefore, there is no energy impact due to this provision. 

Response: This is a matter of differing interpretation of the scope of the 1989 edition. 

We aggregated this comment with 5.1, 8.3,9.4, and 10.3 regarding increase energy 

efficiency due in part to inclusion of existing buildings in 1999 edition. We included it in 

the background section of the determination to reflect this opinion with counter points in 

11.1 and 11.5. 

The memorandum referenced in the comment was written to request the ASHRAE 

Standards Committee to change the scope of the 1999 edition to include renovations to 

existing buildings. The scope of the 1999 edition was subsequently changed accordingly. 

The1989 edition specifically applies to "new" buildings in both the purpose and scope 

statements of that standard. (Section 1 1.2, 2.1 and 2.2) By specifically identifying "new 

systems and equipment in existing buildings" in the scope of the 1999 edition, States 

adopting the 1999 edition in whole or by reference include this provision, which will 

provide significant energy savings over codes equivalent to the 1989 edition. 

ASHRAE in its comment on the analysis disagrees with the interpretation in this comment 

by stating: "It also should be noted that because Standard 90.1-1 999 applies to 

renovations and retrofits to existing buildings, which are not covered in 90.1-1989 . . . " 

(See comment 9.4). 

ASHRAE Standard 100, Energy Conservation in Existing Bzdildings was ASHRAE7s 

definitive work on existing buildings. In particular, the scope of Standard 100 specifically 

 6450-01-P COMMENT 18
describes building and equipment modification provisions that must be met for a building 

or building complex to comply with this standard. 

The most recent update to this standard is ANSI/ASHRAE/IESNA 100-1995. This 

standard supersedes Standard 100.2- 199 1, Standard 100.3- 1985, Standard 100.4- 1984, 

Standard 100.5-1 99 1, and Standard 100.6-1991. The fact that the standard was upgraded 

after 1992, DOE'S baseline of comparison established by Section 101 of the Energy 

Policy Act of 1992, shows that this was still the appropriate document for existing 

buildings at the time the memorandum cited in the comment was written. 

We note that through the mid 1990s the American National Standards Institute recognized 

the ASHRAE Standard 100 series, that explicitly addressed existing buildings. Under 

American National Standards Institute policy, two standards (Standard 90.1-1989 and 

ASHRAE Standard 100) could not address existing buildings. 

See also comments by others noted at the top of this response. 

11.3. Subjective analysis. 

B. Detailed Textual Analysis. The fourth paragraph of this section states, "In comparing 

the envelope requirements we made judgments of relative stringency and frequency of occurrence 

of components. A positive or negative national energy impact was then estimated, based on 

practical application of the design requirements in each edition" (emphasis added). We are 

deeply concerned that the apparent subjective nature of the analysis of the envelope section 

allowed ample opportunity to introduce the biases of the analystts), bringing the credibility of the 

analysis into question. The fifth paragraph of this section states, "We focused on the prescriptive 

compliance paths in each section, which we believe represent the most common approach to 

using the standard in question for most buildings." The author, however, provides no basis for 

drawing this conclusion. It has been argued that the prescriptive conlpliance path may reflect 

common practice in the field better than the performance path as it applies to the 1989 standard. 

Due to the disparity in stringency between the prescriptive and performance paths, a lighting 

design that exceeds the maxiinurn allowance using the whole building method may still be in 

compliance if the space-by-space method is used. Since this situation is possible, the whole 

building method does not always act as a true limit on the lighting power by the standard. The 

true limitation often ends up being the lighting power allowance under the space-by-space 

method. This situation is even more likely under the 1999 standard than the 1989 standard since 

the space-by-space method has been simplified. 

Response: See response to comment 12.6.1. Combine with comments1 2.6 and 12.6.1. 

Also, while we focused on the prescriptive compliance paths in each section, which we 

believe represent the most common approach to using the standard in question for most 

buildings, we also believe it to be the most reliable way to make the comparison. Reliable 

data on the number, quantity, and characteristics of spaces in the commercial building 

stock is not available. Hence, we do not believe that it is appropriate for this analysis to 

 6450-01-P COMMENT 18
create prototype buildings that purport to represellt these characteristics with any 

accuracy. 

This comment reflects a differing opinion on the most appropriate approach to the 

analysis. In the determination, we grouped this with comments on exit signs, the use of 

the prescriptive compliance path and not the performance paths in the analysis, our 

conclusions on the lighting power exemptions, window thermal transmittance and solar 

heat gain, temperature reset controls, and heating equipment. 

11.4. Performance versus prescriptive compliance path. 

In addition, our experience from working with consulting engineers and design-build 

contractors on commercial projects is that design engineers seek to value-engineer their designs 

(i.e., maximize flexibility to arrive at design solutions that provide optimum benefit to the 

building occupants, while keeping first cost at a minimum). To gain this degree of flexibility with 

both Standard 90.1-1989 and Standard 90.1-1999, the designer must use the performance 

compliance path rather than the prescriptive path in each section. Resistance to using the 

performance approach was further lowered with the release of Standard 90.1 - 1999 by a greatly 

simplified performance compliance path. It seems likely that the real motive for using the 

prescriptive rather than performance compliance path is that the additional flexibility in the 

performance path, especially in Standard 90.1 - 1999, increases the allowable energy power levels 

in many applications thereby decreasing the energy savings potential of the new standard. 

Response: We have experienced a strong demand for prescriptive requirements for 

standards throughout the revision process leading up to the 1999 edition. The purpose is 

to provide prescriptive requirements for the majority of buildings constructed so as to 

provide requirements that meet the need of the large number of relatively small and simple 

buildings constructed. 

Furthermore, the Standards Hotline has received numerous calls on the application of the 

1989 edition for all sections, including lighting. The vast majority are on the use of the 

prescriptive tables or on the use of COMcheck. Both are related to the prescriptive path. 

The flexible compliance paths (e.g., tradeoff methodologies and the Energy Cost Budget 

Method) are generally used only if the flexibility is needed by the designer for compliance 

or if specific tools are developed which can make their use the low first cost method of 

design. 

This comment reflects a differing opinion on the most appropriate approach to the 

analysis. In the determination, we grouped this with comments on the subjective nature 

of the analysis of the envelope section, exit signs, our conclusions on the lighting power 

exemptions, window thermal transmittance and solar heat gain, temperature reset controls, 

and heating equipment. 

 6450-01-P COMMENT 18
11.5. Existing buildings. 

11. Discussion of Detailed Textual Analysis; A. Title and Scope. The discussion of the 

application of Standard 90.1- 1999 to alterations and renovations to existing buildings implies that 

energy use reduction in this building segment could be significant. While acknowledging that "it 

is difficult to quantify the energy efficiency impact of alterations and renovations," the 

implication is that it could approach 50 percent of the energy use reduction from new 

construction. Since there is absolutely no basis for this assertion, this implication is wholly 

inappropriate. In addition, the assertion that the explicit application of the 1999 standard to 

alterations and renovations to existing buildings greatly expands the scope of the standard beyond 

the 1989 additions is highly questionable (see previous discussion under Detailed Textual 

Analysis, Section 1 .A). 

Response: We combined this comment with comments 5, 8.3, 9.4, 10.3, and 11 .l. Some 

of the most common renovations to commercial buildings are lighting and equipment 

replacement and/or renovation. Lighting renovations in particular are done on a regular 

basis in many commercial building and generally it is in these two areas where the1999 

edition has made great strides forward in terms of system efficiency. Envelope changes, 

which are considerably less colnmon in commercial building renovation, is an area where 

the 1999 edition is less stringent for some building constructions. Hence, the savings in 

energy use intensity may actually be higher for renovation square footage than for new 

construction. The language in the textual analysis does not state that renovations will 

provide 50 percent of the energy saved by 90.1-1 999 for new construction, but rather 

points out that the dollar value of renovations is close to 50 percent of the dollar value for 

new comlnercial construction. 

Comments from ASHRAE state that industry estimates indicate that at least 60percent of 

heating and cooling equipment sales are for replacement markets, and only 40percent for 

new buildings. (See comment 9.4) 

11.6. Interior lighting power exemptions. 

B. Lighting and Power; 1. Interior Lighting Power Exemptions. After listing a number of 

lighting system exemptions in both Standard 90.1 - 1989 and Standard 90.1 - 1999, the author 

concludes that "the net effect of these differences is expected to be a small increase in efficiency 

in the 1999 edition." Without providing any verifiable basis, making such an assertion is 

inappropriate. In addition, some of the claimed lighting power exemptions are factually incorrect. 

For example, the claim "lighting for outdoor manufacturing, commercial greenhouses, and 

process facilities; and special lighting for research are exempt in the 1989 edition but not in the 

1999 edition" is incorrect. The scope of Standard 90.1-1 999 specifically exempts "equipment 

and portions of building systems that use energy primarily to provide for industrial, 

manufacturing or commercial processes." Also, the claim "lighting integral to open and glass 

enclosed refrigerator and freezer cases, and lighting integral to food warming and preparation 

equipment lighting in interior spaces that have been designated as a registered interior historic 

landmark . ..are not generally controlled by the 1989 edition because they are rarely known at the 

 6450-01-P COMMENT 18
time the lighting plans are approved" is incorrect. These lighting systems are integral to the 

building design and specified by the building designer. 

Response: The statement that, the net effect of these differences is expected to be a small 

increase in efficiency in the 1999 edition, is a reasonable subjective judgement provided 

in lieu of the availability of quantifiable data. 

We believe the scope exception to processes does not apply to lighting unless the lighting 

is there to provide for processes, such as drying or heating lights in a production process. 

The overhead lighting in a process portion of a plant provides lighting to the labor force in 

order to perform their work and to move safely around in the space and is therefore not 

exempted. This is the same rational that is applied to heating or cooling equipment that is 

required to comply, because it is used for labor force comfort versus heating and cooling 

equipment that is exempted because it is used for the processing of materials. The1 999 

edition has explicit lighting requirements for manufacturing facilities, workshops, and 

warehouses even though these buildings exist to support processes. 

This comment reflects a different interpretation of lighting power exemptions than the one 

we hold. In the determination we grouped it with comments having to do with differing 

interpretations of lighting integral to equipment, transformers, transportation systems, 

energy management systems, and the energy cost budget compliance path. 

We disagree with the portion of the comment regarding lighting that is integral to open 

and glass enclosed refrigerator and freezer cases and lighting that is integral to food 

warming and preparation equipment. The point is not that they are integral to the building 

design and specified by the building designer. The point is that detailed information on 

this lighting is rarely known at the time lighting plans are approved by the code official. 

This is our experience and that of other lighting designers we have talked to. 

This portion of the comment also reflects a different interpretation of the exemptions than 

we have. In the determination we grouped the comment with comments having to do with 

differing interpretations of lighting power exemptions, transformers, transportation 

systems, energy management systems, and the energy cost budget compliance path. 

The portion of the comment that states, " . . . and preparation equipment lighting in 

interior spaces that have been designated as a registered interior historic landmark ... are 

not generally controlled by the 1989 edition because they are rarely known at the time the 

lighting plans are approved" (italics added), misquotes and distorts our statement. The 

original statement on historic landmarks is correct. 

This comment reflects a differing opinion on the most appropriate approach to the 

analysis. In the determination, we grouped this comment with comments on the subjective 

nature of the analysis of the envelope section, exit signs, the use of the prescriptive 

 6450-01-P COMMENT 18
compliance path and not the performance paths in the analysis, window thermal 

transmittance and solar heat gain, temperature reset controls, and heating equipment. 

We have made no change to the draft analysis in response to this comment. 

11.7. Exterior lighting power. 

2. Exterior Lighting Power. The first paragraph of this section indicates that under 

Standard 90.1-1 999 the allowable lighting level for entrances without canopies increases while 

the allowable lighting level for entrances with canopies decreases, and draws the conclusion that 

the "net impact is an overall energy savings with the 1999 edition." Without quantifying the 

number of canopied and uncanopied entrances as well as the area involved, there is no basis for 

reaching this conclusion. The second paragraph of this section indicates that all lighting power 

density requirements have been eliminated from the 1999 standard and instead sets an efficacy 

requirement for luminaries used, and concludes that it is impossible to ascertain whether this will 

lead to a net decrease or increase in energy use. Given the tendency of lighting designers to use 

exterior lighting as a key architectural element in building design, it seems quite probable that this 

provision would result in an increase in lighting energy. 

Response: We agree that there is no basis for reaching a conclusion with regards to the 

combination of a 5 Watts per linear foot reduction for all building exits and a 1 to 7 Watts 

per square foot reduction for all canopied entrances, a 3 Watts per linear foot increase for 

uncanopied entrances, and the added efficacy requirement that applies to entrance and 

exit lighting that is more than 100 Watts. Data on the number and characteristics of 

building entrances and exits is not available. We have changed our draft analysis to 

reflect this. 

The second paragraph, in this section of the textual analysis, does not state that all lighting 

power density requirements have been eliminated from the standard. Rather it points to 

specific areas where they have been eliminated (i.e., loading areas, loading doors, storage 

and non-manufacturing work areas, and driveways, walkways, and parking lots). We also 

disagree with the claim that there is a lighting trend that would result in an increase in 

lighting energy. No data is provided and we do not find the statement to be compelling. 

Accordingly, no change to the draft analysis has been made in response to this comment. 

11.8. Interior lighting controls. 

3. Lighting Controls - Interior. The first paragraph in this section discusses the two 

different approaches to establishing minimum lighting control requirements used in Standard 

90.1- 1989 and Standard 90.1 - 1999. Although the n~inin~um criteria used in the new standard (i.e., 

automatic lighting shutoff) seems to be much simpler than the criteria used in the old standard 

(i.e., control points), it is hard to see how the change will produce energy savings during 

unoccupied hours as stated in the analysis. The second paragraph in this section discusses the 

mandatory requirement for manual, automatic or programmable controls in Standard 90.1 - 1989 

compared to the requirement for automatic controls in Standard 90.1-1999 and concludes that the 

 6450-01-P COMMENT 18
latter provision is "more likely to reduce lighting energy use." This conclusion presupposes that 

in a significant number of instances that manual controls are being used in lieu of automatic and 

programmable controls under the 1989 standard, however, there is no basis for drawing that 

conclusion. The third paragraph in this section discusses the use of lighting control credits in 

Standard 90.1 - 1989 compared to the use of automatic controls without credits in Standard 90.1 - 

1999 and concludes that "this allows more lighting to be used." While at first glance it may 

appear that this provision allows for greater lighting energy consumption in buildings utilizing 

approved lighting control devices, the intent of the standard is that the higher allowed lighting 

power densities will be more than offset by the reduced operation of lighting systems controlled 

with these devices. This intent is made clear by the ASHRAE/IES Standard 90.1 -1989 User's 

Manual, which states: 

"The value ofpower adjustment are determined by a consensus of experts. These 

values are supported by experience and substantial (although not absolutely 

conclusive) evidence of relative effect. The values are intentionally conservative, 

since in actual practice a control device may not perform as advertised or be 

rendered inoperative by improper installation and adjustment." 

Response: We disagree. The requirement for automatic lighting shutoff in all 

spaces, using time of day, occupancy sensor or similar methods, is explicitly 

directed at turning off lights when people are not there, thereby producing energy 

savings during unoccupied hours. 

The basis of the assertion, that the requirement for automatic controls in the 1999 

edition is more likely to reduce lighting energy use, is that it is mandatory and not 

merely optional, as in the 1989 edition. While the 1989 standard optional control 

points could rely on automatic controls, there is no language suggesting they must 

rely on automatic controls. 

The comment explains that the intent of the 1989 edition control credits is that the 

higher allowed lighting power densities will be more than offset by the reduced 

operation of lighting systems controlled with these devices. This is correct. 

However, it ignores the fact that the 1999 edition requires the use of automatic 

controls without allowing an increase in connected power. Hence, the 1999 

edition should save the same energy as offset by controls in the 1989 edition, plus 

the energy saved by not increasing the allowed lighting power densities, as the 

1989 edition increases them. 

We have made no change to the draft analysis in response to this comment. 

1 1.9. Exit signs. 

5. Exit Signs. The section discusses the minimuin requirements in the 1999 standard for 

all exit signs, which will essentially eliminate the use of incandescent exit signs. However, since 

 6450-01-P COMMENT 18
the 1989 standard does not contain any explicit criteria for exit signs, the conclusion that this will 

"thereby reducing energy consumption" does not necessarily follow. 

Response: We disagree. There will be energy savings where the scope of the 1999 

edition is increased to include requirements on building lighting or equipment, that did not 

exist in the previous edition. There will also be energy savings when the new efficiency 

requirement either constrains the allowed energy use or requires an efficiency greater than 

some fraction of the existing market. Incandescent exit signs are marketed and sold today 

that currently do not meet the efficacy requirements of the 1999 edition. 

This comment reflects a differing opinion on the most appropriate approach to the 

analysis. In the determination, we grouped this with comments on the subjective nature 

of the analysis of the envelope section, the use of the prescriptive compliance path and not 

the performance paths in the analysis, our conclusions on the lighting power exemptions, 

window thermal transmittance and solar heat gain, temperature reset controls, and heating 

equipment. 

We have made no change to the draft analysis in response to this comment. 

11.10. Interior lighting power. 

6. Interior Lighting Power - Whole Building The first paragraph of this section implies 

that the 1999 standard treatment of luminairehallast combinations could eliminate the underestimation of installed lighting power in the 1989 standard. While the 1999 standard explicitly 

states that luminaire wattage is the wattage of the luminaries with permanently installed or remote 

ballasts or transformers, there is nothing in the 1989 standard to suggest that the luminaire 

wattage is anything other than the total connected load of the lighting fixture. A comparison of 

Standard 90.1-1989 and Standard 90.1-1999 in the second paragraph shows that for some 

building types the older standard has more stringent lighting power requirements, for other 

building types the new standard is more stringent, and in some instances they are substantially the 

same. The analysis concludes that over all building types there is an average reduction of 0.1 1 

Wft2 with the 1999 standard, but further suggests that since the reduction is even greater for 

office and retail building types, the overall impact is a net reduction in energy use. This is not a 

valid conclusion unless the weighted average energy impact of all building type lighting power 

allowances is computed. 

Response: We disagree. Because the 1989 edition does not specifically call out ballast 

energy, the potential for misuse exists. Incandescent sources are always called out by 

their total nominal wattage. Similarly, lamp designations such as, 40 Watt lamp,34 Watt 

lamp, F40T12, F34T12, or F32T8, are all cominon terms for typical fluorescent lamps. 

Each of these designations includes the nominal lamp wattage. The designation does not 

include the combined lamp and ballast wattage. Drawings and other tools reviewed for 

code compliance would typically not show the connected lighting power including the 

ballasts. Also, the lamp and ballast total power consumption is often not readily available 

 6450-01-P COMMENT 18
for fixtures. It is this potential misapplication of the language that has been eliminated in 

the 1999 edition and may lead to increased energy efficiency. 

With regards to the overall impact of lighting between the two editions, our quantitative 

analysis compares a scenario of the 1989 edition's criteria against the 1989 edition's 

criteria, with the 1999 edition's lighting levels substituted. This is done for seven general 

building type categories, using the whole building lighting numbers. The resulting 

comparison shows an overall electricity reduction of 2.56 thousand Btu per square foot 

annually across all building types, a 1.55 thousand Btu per year site energy savings, and a 

7.04 thousand Btu per square foot annual source energy savings. This analysis takes into 

account not just the lighting wattage, but the decreased cooling load and increased heating 

load that result from changes in the internal load density. 

We have made no change to the draft analysis in response to this comment. 

11.1 1. Interior lighting power - space by space. 

Interior Lighting Power - Space-by-Space. The third paragraph in this section describes 

the difficulty in defining a "typical" space for determining the impact of the additional power 

allowances in Standard 90.1 - 1999. While this is undoubtedly true, there is no need to define a 

typical space to compare the impact of this provision. A more valid comparison is achieved by 

establishing the maximum lighting power allowed by the standard, which can be easily 

ascertained by values tabulated in the standard. In addition, the complexity of determining 

additional lighting power allowances for retail spaces is overstated by the statement that the 

"application of these allowances will depend on the layout of the retail space and how and for 

what height the lighting is employed." This is only partially correct, as only how the space is used 

will impact the deployment of the additional lighting. The maximum lighting level, expressed in 

Wlft ', is not impacted by the layout of the space or the height at which the lighting is employed. 

A careful analysis of Table 1 reveals that the author is assuming, in most instances, area factors 

that are too high for the space types indicated. This assumption has the effect of overstating the 

effective total lighting power under the 1989 Standard, thereby, overstating the total lighting 

power reduction due to the 1999 Standard. Although not explicitly stated in the analysis, the 

underlying area factor assumptions can be easily determined by dividing the 1989 Edition 

Adjusted Total Power values by the unit power densities provided in the 1989 Standard. Using 

this method, it can be shown that the author is using an area factor of 1 .OO for computing the 

1989 Edition Adjusted Total Power values for the Mass Merchandising and Food and 

Miscellaneous Retail space types and an area factor of 1.32 for all remaining spaces (see attached 

Table IA). The area factor, as defined in the 1989 Standard, is a function of the area and the 

ceiling height of the specific space. While both the area and ceiling height will vary from building 

to building, a range of values can be identified that are fairly representative for the space. Using 

the graphs provided in the 1989 Standard a space with an area over 5,000 ft%nd a 10-foot 

ceiling height would result in an area factor of 1 .O. This value, therefore, seems quite reasonable 

for the Mass Merchandising and Food and Miscellaneozrs Retail space types. However an area 

factor of 1.32, which the analysis uses for all other spaces, would result in ceiling heights of 16 

 6450-01-P COMMENT 18
feet for a 1000 ft2 space, 24 feet for a 2500 ft" space, 32 feet for a 5000 ft2 space, and over 36 

feet for spaces in excess of 7500 ft2. Clearly, this is not a representative area factor for the space 

types shown in Table 1. The conclusion from the analysis, that with the exception of the OfficeEnclosed, Office-Open and Jewelry Retail "the 1989 edition lighting values cannot be achieved 

without additional lighting power scenarios that are generally unreasonable for the space type," is 

also dubious. To better ascertain the real impact of the additional lighting power allowances 

provided in the 1999 Standard, Table 1 was recreated using areas and ceiling heights more 

representative of the specific spaces shown (see attached Table IB). Using this approach, an area 

factor of 1 .OO was computed for the Hotel Lobby, Office-Open, Mass Merchandise Retail, 

Department Store Retail, Food and Miscellaneous Retail and Mall Concourse spaces, an area 

factor of 1.05 was computed for the Jewelry Retail, Fine Merchandise Retail and Service Retail 

spaces, and an area factor of 1.50 was computed for the office-enclosed space. Using these area 

factors, all additional lighting power allowances are likely to be used in all spaces except the 

Office-Enclosed, Office Open and Jewelry Retail, and in the case of the latter, the entire 

additional lighting power allowance could be used and still be within full compliance of the 1999 

Standard. The DOE analysis reaches the conclusion that "the 1989 edition lighting values are 

more stringent, with the additional lighting power allowances more than compensated for by the 

reduction in base lighting power in the 1999 edition." However, if more reasonable area factor 

assumptions are made for all space types, this is not the case. Based on our analysis, if the 

maximum lighting power allowed by the 1999 Standard is used and reasonable space allocation 

assumptions are used, the allowable lighting power levels under the 1999 Standard are 26 percent 

higher than the 1989 Standard for those spaces for which additional lighting power allowances 

are applicable (see attached Table 1 C). 

 6450-01-P COMMENT 18
Table 1A. Calculation of Assumed Area Factors and Additional Lighting Type Used 

Notes: 

12. All additional power allowances likely to be used with additional lighting type indicated. 

13. 1989 lighting power letels carulot he achieved with additional ligfiti~ig type indicated, even with the rnaxitnum additional power allowa~ice applied 

14. Lighting power values cannot be achieved with additional lighting type uidicated without 'knreasonable" additional lighting power allowances. 

15. 1989 Edition Assumed '4rea Factor = 1989 Edition .4cijusted Total Power (Wft2) 1989 Edition Base Power (W!ft2) 

Space Type 

(Additional Lighting Type) 

Hotel Lobby 

(Decorative) 

Office - enclosed 

(Visual Display Tennulal) 

Office - Open 

(Visual Display Terminal) 

Jewelry Retail 

(Highlight Merchandise) 

Fine Merchandise Retail 

(I-Iighlight Merchandise) 

Mass Mercha~~dise Retail 

(Highlight Merchandise) 

Department Store Retail 

(Highlight Merchandise) 

Food & Misc. Retail 

(Highlight Merchandise) 

Service Retail 

(Highlight Merchandise) 

Mall Concourse 

(Highlight Merchandise) 

Textual Analysis Table 1 - DOE Analysis (Table 1A) 

1989 Edition 

Base Power 

(Wifty 

1.90 

1.80 

1.90 

5.60 

3.20 

3.30 

3.10 

2.80 

2.70 

1.40 

1989 Edition 

Assumed Area 

Factor ' 

1.32 

1.32 

1.32 

1.32 

1.32 

1 .OO 

1.32 

1 .00 

1.32 

1.32 

1989 Edition 

Adjusted Total 

Power (W!fi2) 

2.5 1 

2.38 

2.51 

7.39 

4.22 

3.30 

4.09 

2.80 

3.56 

1.85 

1999 Edition 

Base Power 

(Wilt2) 

1.80 

1.50 

1.30 

2.10 

2.10 

2.10 

2.10 

2.10 

2.10 

1.80 

Add. Power 

Allowance 

(wlft') 

1 .OO 

0.35 

0.35 

3.90 

3.90 

1.60 

3.90 

1.60 

1.60 

1.60 

Max. 1999 

Value 

(W!fi2) 

2.80 

1.85 

1.65 

6.00 

6.00 

3.70 

6.00 

3.70 

3.70 

3.40 

VDT 

% 

100.00 

100.00 

Max. Space w/ 

Add. Lighting 

(%) 

71.00 1 

100.00 2 

100.00 2 

100.00 2 

55.00 3 

75.00 3 

51.00 3 

43.00 3 

92.00 3 

3.00 1 

Decorative 

YO 

70.80 

Gen. 

Merchandise 

(%) 

75.00 

43.75 

91 .SO 

3:00 

Fine 

Merchandise 

(%) 

100.00 

54.46 

51.08 

 6450-01-P COMMENT 18
rable 1B. Are Factors Based on More Reasonable Building Characteristics 

Notes: 

I. All additional lighting power allowances likely to he used. 

2. 1989 lighting power levels cannot he achieved, eve11 with the rnaximum additional power allowance applied. 

3. Lighting power values camot he achieved if inaximurn allowable additional lighting power allowances are used. 

4. 1989 Edition Assumed Area Factor = 1989 Edition Adjusted Total Power ((W/A2)/1989 Edition Base Power (WIA?. 

Fme 

Merchand~se 

(%) 

96 92 ' 

3231 ' 

25 64 ' 

Textual Analysis Table 1 - DOE Analysis (Table 18) 

Gen 

Mercl~and~e 

(%) 

60 00 ' 

43 75 ' 

45 94 ' 

(25 00) ' 

Space Type 

(Add~tlonal Llghting Tyye) 

IIotel Lobby 

(Decoratfve) 

Office - erlclosed 

(V~sual D~splay Tennu~at) 

Office - Open 

(V~sual D~splay Termmal) 

bwehy Retad 

(Hlghhght Merchandtse) 

F~ne Merchatld~se Retall 

(131ghhgllt Mercha~ldse) -- - 

Mass Merchand~se Retall 

(Htghl~ght Merchandae) 

Department Store Retall 

(H~gbhght Merchandae) 

Food & Mlsc Retall 

(H~ghl~ght Merchandsc) 

Semce Retall 

(H~ghl~ght Merchand~se) 

Mall Cor~course 

(Hlghhght Mercha~~dtse) 

Add 

Power 

tZIlowance 

(Wlft') 

1 00 

0 35 

0 35 

3 90 

3 90 

1 60 

3 90 

1 60 

1 60 

1 60 

Typ Space 

Sue (ft2) 

10,000 

100 

5,000 

2,500 

2,500 

5,000 

10,000 

10,000 

2,500 

10,000 

Max 1999 

Value 

(~Ift~) 

2 80 

I 85 

1 65 

6 00 

6 00 

3 70 

6 00 

3 70 

3 70 

3 40 

Max Space 

w I 

Add L~ghtuig 

(yo) 

71 00 

1 

100 00 

2 

100 00 

2 

100 00 

2 

55 00 

3 

75 00 

3 

51 00 

3 

43 00 

3 

92 00 

3 

3 00 

1 

Typ 

Ce1111lg 

Nelght 

(ft) 

15 

10 

10 

10 

10 

I5 

15 

15 

10 

15 

1989 Edd~on 

Adjusted 

Total 

Power (WIft2) 

1 90 

2 70 

I 90 

5 88 

3 36 

3 30 

3 10 

2 80 

2 84 

1 40 

Decoratwe 

O/n 

10 00' 

1999 Ed~t~on 

Base Power 

(w/ft2) 

1 80 

1 50 

1 30 

2 10 

2 10 

2 10 

2 10 

2 10 

2 10 

I 80 

1989 Eda~on 

Base Power 

(~lft') 

1 90 

1 80 

1 90 

5 60 

3 20 

3 30 

3 10 

2 80 

2 70 

1 40 

VDT 

% 

100 002 

100 00 

1989 Ed~t~on 

Assumed 

Area 

Factor ' 

1 00 

1 50 

1 00 

1 05 

I 05 

1 00 

1 00 

1 00 

1 05 

1 00 

 6450-01-P COMMENT 18
Table 1C. Comparison of Maximum Allowable Lighting Levels Using More Reasonable Building Characteristics 

Notes: 

1 Typical application of additional power alkowancz likely to result in lighting power increase over 1989 standard. 

2 Typical application of additional power allowance not likely to result in lighting power inaease over 1989 standards. 

3 Additional lighting power allowance applied to entire space. 

4 Additional lighting power allowal~ce applied to entire space as follows: 80% general mercha~~dise, 2Ooh fule mercl~andise. 

5 Additional lighting power allowatlce applied to 20 percent of space. 

Space Type 

(Additional 

Lighting T.ype) 

Hotel Lohhy 

(Decorative) 

Ofice - enclosed 

(Visual Display 

tcnnind) 

Ofice -@en 

(Visual Display 

Terminal) 

Jerwlry Retail 

c H~ghligl~t 

Merchandise) 

Fine 

Mercbaadzs~. 

Retail 

(H,@ll,&t 

Merchandise) 

Mass 

Merclia~~dise 

Retail 

(Hlpbil-&i 

Merchandise) 

Depamlreiit 

Store Retail 

(FI~&ligllt 

Mercllandise) 

FOO~ r~: M>SC 

Retail 

(lil&l~@lt 

Merchandise) 

Senrice Retail 

(Highlight 

Merchandise) 

Mall Cm~course 

(Hiphlight 

Mercltandise) 

Tp Space 

Size (R') 

10.000 

100 

5,000 

3.500 

2.500 

5.000 

10.000 

10.000 

2,500 

10.000 

1989 Edition 

Base Power 

(W.A2) 

1.90 

I .80 

1 90 

5.60 

3.20 

3.30 

3 10 

2 80 

2 70 

1 40 

TT 

Ceiiinp 

He~pht (A) 

15 

I0 

10 

I0 

10 

I5 

IS 

IS 

10 

I5 

1989 Edition 

Assumed 

Area Factor * 

I .00 

I So 

1 .00 

I 05 

1.05 

1 00 

1.00 

I oo 

I 05 

1 00 

1989 Edition 

Adjusted Total 

Power (W!A1) 

1 90 

2 70 

1.90 

5.88 

3.36 

3.30 

3.10 

z 80 

2.84 

1.40 

Add Power 

.4.lloW&) 

1 .00 

0.35 

0 35 

3 90 

3.90 

1.60 

3 90 

1.60 

I 60 

1.60 

1999 Edition 

Bam%r 

1.80 

1.50 

1 30 

2.10 

2.10 

2.10 

2.10 

2.10 

2 I0 

1 80 

Max. 1999 

ValdWIR') 

2.80 

I 85 

1 65 

6 00 

6.00 

3.70 

6.00 

3.70 

1.70 

3.40 

Increase 

Over 1989 

Lrvels (%) 

47 

(31) 

(13) 

2 

79 

12 

94 

32 

31 

143 

Max. Space 

W'Add. 

I.~ghtxf&j 

71.00 

10000 

100.0 

I00 00 

55.iXI 

75 00 

51 N 

43 00 

92.(X) 

3.00 

I999 Value 

w'?4 Add 

Ltg(Bb@ 

2.51 

1.85 

1.65 

6.00 

4.25 

3.30 

4.09 

2 79 

3.57 

1.85 

hlcrease 

Over 1989 

Levels (%j 

32 

(31) 

(13) 

2 

26 

0 

32 

(0) 

26 

32 

Reasonable 

Lighting Power 

Scenario (%) 

100.00 3 

10000 3 

IMiOO 3 

100.00 3 

10000 3 

100.(10 4 

100.00 4 

Inow 3 

I0000 3 

20.00 5 

1999 Value w? 

'?o Add. Ug. 

Shown (U' A') 

2.80 

1.85 

I .65 

600 

6 00 

4.16 

4 16 

3.70 

3 70 

2.12 

Increase 

Over 1989 

Levels (5) 

47 ' 

131) ' 

(13) ' 

2' 

79 ' 

26 

34 ' 

32 I 

31 ' 

51 ' 

 6450-01-P COMMENT 18
Includer hghtmg power rncreases deemed unreasonable to DOE Textual Analysn 

Includes maxrtnum Ilghtutg power allowed by 1999 standard, allocated as noted 

1989 Ed~tan Assuui~ed Area Factor = 1989 Edltioii Adjusted Total Power (w/ft2)11989 Edrtlon Base Power (w/ft2) 

 6450-01-P COMMENT 18
Response: We disagree with the comment suggesting that the maximum lighting power 

density possible for a particular space is the appropriate basis for establishing the impact 

of the additional power allowances in the 1999 edition. This edition allows additional 

lighting power, but only for specific luminaries, perfonning eligible lighting functions 

occurring in a specific space. It allows additional lighting power to meet the requirements 

of visual display terminals, to highlight certain high end merchandise, and for decorative 

purposes, such chandeliers or sconces for highlighting art. For example, additional 

lighting power for sconces used to highlight art may be used in office lobbies, circulation 

areas, offices, and meeting rooms, but only for a specific sconce(s) illuminating a specific 

piece of art. A casual inspection reveals that art is not displayed in every lobby, 

circulation area, office or meeting room, and when it is, it may not be highlighted. 

Therefore, using the maximum lighting power density for all spaces is inappropriate for 

establishing the impact of additional power allowances. 

We disagree with the comment on the layout of retail space. The use of the phrase 

". . .depend on the layout of the retail space.. ." in describing the 1999 edition lighting was 

meant to refer to those business decisions regarding the layout of sales areas and space 

functions that effect what lighting is needed. It was not used in reference to the physical 

size of the space. The statement in the draft analysis has been clarified to make the point 

clear. 

The issue of appropriate area factors is a central issue when trying to compare the spaceby-space requirements of these two editions. Accurate data on the actual room cavity ratio 

or area factor of representative spaces is not available. The area factor values we used for 

this comparison were those exacted from the room cavity ratio values used for these space 

types in development of the 1999 edition. These data will necessarily be quite variable, 

given that space types vary greatly in size. We reviewed the individual space type 

assumptions used and note the following: 

Our assumption for lobbies was incorrect. For the hotel lobby category, our review of the 

rooin cavity ratio and area factor assumption shows an error with this space type. The 

1999 edition applied a room cavity ratio category of 1.0 for the hotel" lobby category 

which equates to an area factor of 1.0 instead of the area factor of 1.32 used in our draft 

analysis. This room cavity ratio category, used in the development of the draft analysis 

table, was the basis for all other lobby types. Correcting this category changes the lighting 

power density from the 1.8 Watts per square foot, shown in our table, to 1.7 Watts per 

square foot. Under this latter scenario, it is estimated that 20 percent of the space would 

need to have additional decorative lighting, in order to match the lighting power density 

allowance in the 1989 edition. We agree that this is a reasonable amount of decorative 

lighting in such a space type and changed the draft analysis to reflect this. We have 

changed the text of the draft analysis accordingly. 

We have reassessed the area factor for the space category, office-open spaces. And we 

have changed the area factor. But this does not change our conclusion. For the office- 

 6450-01-P COMMENT 18
open space type, an area factor of 1.32 was used, based on the original 1999 lighting 

work. Upon review, this seems high, when considering the typically larger spaces 

associated with open offices, with standard 8 foot to 10 foot ceilings. Part of the 

committee rational for a higher room cavity ratio, and therefore an area factor, deals with 

the common use of partitions or cubical arrangements for these spaces. The established 

room cavity ratio calculation for these types of partitions involves the consideration of the 

typically 5-foot high box arrangement of each cubicle. The room cavity ratio for a space 

so divided is radically different from the same area without partitions. An unpartitioned 

office, with an area factor of 1.0 is reasonable. Such an office would be allowed 1.9 

Watts per square foot lighting power density in the 1989 edition. Such a lighting power 

density would still exceed, by a wide margin, the maximum 1.65 Watts per square foot 

allowed in the 1999 edition. 

We agree with the comment that area factors we used for our draft analysis equate to 

spaces that are on the small side for the categories of department store and mall retail, but 

we find the area factors suggested in the comment inappropriate. For the categories, 

department store and mall retail, an effective area factor of 1.32 equates to spaces with 14 

to 24 foot ceilings, and floor areas between 800 and 3000 square feet. However, an area 

factor of 1 .O, suggested in the comment, equates to spaces with floor areas above 14,000 

square feet, which would be inappropriate for a significant number of such retail category 

space types. 

A review of the retail space categories of jewelry, fine merchandise, and service retail 

suggests that most of these areas will not have high ceilings, but rather moderate ceiling 

heights of 8 to 12 feet. At an area factor of 1.32 the room areas would vary between 200 

and 600 square feet, which would be appropriate for smaller shops and service areas. To 

arrive at an area factor of 1.05 with the same ceiling height range would require floor 

areas between 1,300 and 4,000 square feet. While all these space sizes exist for these 

space types, floor areas of 200 square feet is sinall and 4,000 square feet is large. A more 

reasonable area factor for these space types would fall between 1.05 and 1.32. 

Using the lower area factor values proposed in the comment, jewelry stores would require 

more than 97 percent of the space to be filled with highlighted jewelry, which 

isimpossible. Spaces housing fine merchandise would require 79 percent of the space to 

be filled with such merchandise and lit with general highlighting or 32 percent of the 

space lit to highlight fine merchandise. This is improbable, but conceivable in some 

stores. 

Neither scenarios for the department store nor the mass merchandise space categories are 

reasonable. These spaces would require 62 percent or 75 percent (respectively) of their 

spaces to be occupied with merchandise eligable to be highlighted to meet the lighting 

power densities of the 1989 edition. At most, 70 percent of these spaces contain goods. 

The remainder of the spaces are allocated to aisles, checkout counters, and entrances and 

exits. These latter areas would not be eligible for the additional lighting allowance. 

 6450-01-P COMMENT 18
We agree that the table should show ranges of area factors and have revised the draft 

analysis accordingly. 

We have revised the text and table in the draft analysis to reflect the above. See the table 

below. 

 6450-01-P COMMENT 18
Table 5. Additional lighting power allowance in the 1999 edition needed to match the 1989 

edition lighting power allowance. 

Space Type 

[Additional Lighting Type] 

Hotel Lobby 

[Decorative] 

Office - enclosed 

[Visual Display Terminal] 

Office - open 

[Visual Display Terminal] 

Jewelry Retail 

[Highlight Merchandise] 

Fine Merchandise Retail 

[Highlight Merchandise] 

Mass Merchandise 

(big box) Retail 

[Highlight Merchandise] 

Department Store Retail 

[Highlight Merchandise] 

Food and Misc. Retail 

[Highlight Merchandise] 

Service Retail 

[Highlight Merchandise] 

Mall Concourse 

[Highlight Merchandise] 

Possible Scenarios of use of additional power in 1999 

edition to equal 1989 edition value 

Permits 20 percent of the entire space to have 

decorative lighting 

Cannot reach the1989 edition's value (Max 1999 value 

= 1.85) 

Cannot reach the 1989 edition's value (Max 1999 value 

= 1.65) 

In most cases one cannot reach the 1989 edition's value 

(Max 1999 value = 6.00). Need to have 97 percent of 

the entire space covered with spotlighted fine 

merchandise displays, to reach the 1989 edition's lower 

value. 

Need to have between 32 and 55 percent of space 

dedicated to spotlighted fine merchandise displays - or, 

more than 78 percent of the space dedicated to 

spotlighted general displays, to reach the 1989 edition's 

value. 

75 percent of space dedicated to spotlighted general 

displays - OR - 30 percent of space dedicated to 

spotlighted fine merchandise displays, to reach the 

1989 edition's values. 

Need to have between 26 and 5 1 percent of space 

dedicated to spotlighted fine merchandise displays, or 

more than 62 percent of the space dedicated to 

spotlighted general displays, to reach the 1989 edition's 

values. 

Need to have 43 percent of space dedicated to 

spotlighted general displays, to reach the 1989 edition's 

values. 

Need to have between 46 and 92 percent of the entire 

space dedicated to spotlighted general displays, to reach 

the 1989 edition's values. 

The 1999 value is within or close to possible 1989 

values 

1989 

Edition 

Adjusted 

Total 

Power 

2.51 

2.38 

2.51 

5.88 to 7.40 

3.36 to 4.23 

3.30 

3.10 to4.10 

2.80 

2.84 to 3.57 

1.40 to 1.85 

1999 

Edition 

Base 

Power 

1.7 

1.5 

1.3 

2.1 

2.1 

2.1 

2.1 

2.1 

1.05 - 1.32 

1.8 

 6450-01-P COMMENT 18
1.1. Envelope air leakage. 

C. Building Envelope; 1. Air Leakage. The conclusions in the second paragraph of this 

section are not consistent with the accompanying table (Table 2). The paragraph should read as 

follows: 

The impact of these changes on energy efficiency is hard to evaluate. Air leakage 

requirements for windows are stringent for six window types, and more 

stringent in one window type in the 1999 edition. Skylight requirements are more 

less stringent in the 1999 edition than in the 1989 edition. Doors are more 

stringent for types less stringent for five types, in the 1999 edition. We 

have no data as to the prevalence of each different type of component and without 

this data, we have determined that the overall impact on energy efficiency is 

minimal. 

Given the total misinterpretation of the tabulated data, any conclusions drawn from the data are 

questionable if not totally erroneous. 

Response: The comment is correct that the overall impact in comparing the requirements 

for window air leakage is a reduction in stringency for windows. Neither operable nor 

jalousie windows are a predominate window types in commercial construction. However, 

fixed frame windows are common and there has been a significant increase in the allowed 

leakage rate in the 1999 edition. We did note that one of the reference standards in the 

1989 edition (vinyl windows and sliding glass doors) has been discontinued. 

There are also increased leakage rates for all categories of wood frame windows and for 

skylights. For doors, there are signifi cant increased leakage rates for wooden doors and 

slight increased leakage for sliding doors. However, for the categories of, commercial 

entrance doors and all other commercial doors, there are expected to be significant 

reductions in allowed leakage. Because of the predominance of commercial steel doors in 

the latter category, we believe that door air leakage requirements are more stringent in the 

1999 edition. 

The 1999 edition also includes additional requirements for loading dock weather seals in 

colder climates (greater than 3,600 heating degree days, base 65 degrees Fahrenheit) and 

also a requirement for vestibules in commercial building entrance doors. These 

requirements are not present in the1 989 edition. The conlbination of the more stringent 

requirements for commercial doors and loading dock and vestibule requirements should 

improve energy efficiency in buildings where they are required. 

As there are generally fewer doors than windows, we expect an overall decrease in 

stringency due to air leakage under the 1999 edition. 

We have changed the draft analysis where appropriate to reflect these comments. 

1.2. Speculative building envelopes. 

 6450-01-P COMMENT 18
3. Speculative Building Envelopes. The DOE analysis discusses the provision in 

Standard 90.1-1 999 that would require the envelope efficiency of a "speculative" building to be 

upgraded if the building use changes from a semi-heated to conditioned space (Section 4.1.2.3), 

and concludes that this would result in no additional energy use compared to Standard 90.1-1989, 

which does not differentiate between semi-heated and conditioned spaces. While this may be 

technically correct, it is unlikely that this provision would or could be enforced by the authorities 

having jurisdiction. 

Response: While we disagree with the comment, we agree that there is an opportunity for 

a building conversion to be overlooked by code officials under the 1999 edition. 

However, the 1999 edition does require renovations and changes in occupancy to be 

addressed, whereas the 1989 edition does not. We believe that under the 1999 edition, in 

most instances, the transition from a semi-heated space (e.g., conversion of a warehouse 

heated for freeze protection only to a conditioned space for other use such as office) 

would entail the addition of heating capacity, and likely cooling capacity in most climates. 

Similarly, changes in lighting would likely occur. Building inspections would normally be 

required which would trigger a review of energy code requirements. Furthermore, such a 

transition generally entails a change in occupancy, a matter closely watched by code 

officials for health and life safety reasons. We have added text explaining this in the draft 

analysis. 

1.3. Envelope thermal transmittance in cold climates. 

4. Envelope Thermal Transmittance in Cold Climates. This section discusses the differing 

set of requirements in Standard 90.1-1989 and Standard 90.1-1999 for building envelope for 

extremely cold climates. However, while the narrative refers to climates with more than 15,000 

heating degree-days, base 65" F (HDD65), the accompanying table (Table 3) compares the 1989 

requirements for climates with more than 15,000 HDD65 with 1999 requirements for climates 

with 16,201 to 19,800 HDD65. This is not an "apples-to-apples" comparison. 

Response: The only U.S. climate in the 1989 or1999 edition's weather data that would 

fall under the "cold climate" requirements would be Barrow Alaska, and thus we expect 

any impact to be negligible. We have added text explaining this in the draft analysis. 

1.4. Skylight thermal transmittance and solar heat gain. 

5. Skylight Thermal Transmittance and Solar Heat Gain. The last paragraph of this 

section concludes only that the 1999 edition solar heat gain coefficient (SHGC) requirement is 

more stringent for virtually all locations in the U.S. compared with the 1989 standard. However, 

it would appear that if both SHGC and U-factor are considered, the overall requirements of the 

1989 standard are more stringent. 

Response: We disagree. The comment states that when looking at both SHGC and Ufactor, the 1989 standard is more efficient, but no basis is provided for that statement. 

 6450-01-P COMMENT 18
There are multiple paths for skylight compliance in the 1989 edition's prescriptive 

section. We have not attempted to weigh all possible paths. Paragraph three of our textual 

analysis quite clearly states that the U-factor requirements of the 1989 standard are more 

stringent. It also states that in many instances, a building would be allowed to have a 

considerably higher total area in skylights using the prescriptive path of the 1989 edition, 

where lighting controls have been installed. We have not concluded whether there is a net 

stringency increase or decrease with skylights under the 1999 edition. We have noted that 

solar heat gain coefficient requirements are more stringent for skylights in the 1999 

edition. The information on commercial building stock roofs and skylights is insufficient 

to reach a net conclusion. 

We have made no change to the draft analysis in response to this comment. 

1.5. Slab-on-grade and below grade wall insulation. 

6. Slab-On-Grade and Below Grade Wall Insulation. After discussing the reduced 

stringency for slab-on-grade and below grade wall insulation requirements in Standard 90.1- 1999 

compared to Standard 90.1-1989, the observation is made that "the magnitude of the impact will 

be tempered by the insulating effect of the surrounding earth." However, since the surrounding 

earth is clearly present regardless of the version of the standard, the magnitude of the impact due 

to the reduction in stringency is not tempered at all. The true conclusion is that the 1999 standard 

will result in increased energy consumption relative to the 1989 standard. 

Response: The original statement holds true, but has been changed to reflect that the 

statement is relative to the other envelope components exposed to the air or sun. The 

reduction of slab-on-grade and below grade wall insulation requirement in the 1999 

edition will result in higher heating loads in cold climates, particularly for small buildings. 

However, it will also reduce cooling loads during much of the year in cooler climates. 

While we suspect that this will increase site energy consumption, it is unknown what the 

net impact on primary energy consumption will be in many buildings. Note that slab edge 

insulation was one feature included in the quantitative analysis. 

1.6. Roof Thermal Transmittance. 

7. Roof Thermal Transmittance. The conclusion of this section is very misleading. The 

discussion acknowledges that the 1999 edition is "less stringent for buildings with insulation 

above deck or metal buildings" and that there is a "predominance of built-up roofs (insulationabove-deck) in commercial buildings." The accompanying table (Table 6) indicates that for 7 out 

of 11 cities the U-factor in the 1999 edition is less stringent than the 1989 standard for these two 

roof types. The analysis is understating this impact by concluding "there is a moderate decrease in 

roof U-factor with the 1999 edition" (emphasis added). The statement "a significant decrease in 

requirements for semi-heated type structures" is very misleading. The contextual implication is 

that there is a decrease in roof U-factor in the 1999 standard whereas there is actually a 

significant increase in roof U-factor with a resulting decrease in stringency. In addition, since the 

 6450-01-P COMMENT 18
tabulated data totally ignores residential buildings, no valid conclusions regarding roof thermal 

transmittance can be made. 

Response: We agree that the results can be more clearly stated. Further analysis was 

done. We do not believe that the database information on roofs is sufficient to produce 

defensible quantitative results, only qualified indications of the impacts. 

We estimated the building footprint area (assumed to approximate the roof area) by 

dividing the floor area by the nurnber of floors for each building type. We then applied 

the Co~mnercial Building Energy Consumption Survey (CBECS) statistical weights to 

each building type, to develop a table of the estimated roof area for each roof surface type 

classification for each of the 18 building use classifications in the 1992 CBECS. There 

are 17 CBECS roof surface classifications, which were aggregated into the three roof 

types in the 1999 standard, as shown in the table below. Where a significant fraction of a 

particular roof surface classification could be divided into one or more construction 

categories, estimates were made of the relative percentage in each category. These 

estimates are shown in parentheses in the following table. Finally, the fraction of 

estimated roof area for each roof construction is shown for non-residential, semi-heated, 

and residential space types. 

1999 Edition 

Roof 

Construction 

Insulat~on 

Entirely 

Above Deck 

Metal 

Bu~lding 

Attic and 

Other 

a) Non-refrigerated warehouse assumed 

b) Lodging bwldings only 

CBECS 1992 Roof 

Surface Classifications 

Built-up, Bult-up & metal, 

Built-up & slm ply, 

Composite, 

Foam/Styrofoam, 

Smgle/multiple ply (33%), 

Shmgles & bult-up (50%) 

MetaliRubber (80%), 

Metal Surfac~ng (80%), 

Smglelmultiple ply (33%) 

Concrete Roof, 

MetaVRubber (20%), 

Metal Surfacmg (20%), 

Other (specify), 

Shingles & metal, 

Shingles & sin1 ply, 

Shingles (not wood), 

Smgleimultiple ply (33%), 

Sh~ngles & built-up (SO%), 

Slate & shngles, 

Slate or tile, 

Wooden materials 

Estimated 

NonResidential 

50.2% 

16.5% 

33.3% 

Roof Area 

SemiHeated " 

45.9% 

32.9% 

21.2% 

Fraction 

Residential 

45.6% 

4.9% 

49.4% 

 6450-01-P COMMENT 18
Metal surfacing (about 13 percent of the floor area) can either be considered part of a 

metal building roof or part of a roof with metal joists, as, for example, are used in big box 

buildings such as Walmarts. The 801'20 split here allocates most of the surfaces to metal 

buildings which are the more prevalent class of new commercial construction. The roofing 

categories of shingleslslate and tilelwooden materials, are likely to be in place on roofs 

with attics or single rafter roofs, because they rely on roof pitch to shed water. The 

remaining categories cover a variety of combinations of materials, mainly syntheticlrubber 

surfaces. Some of these may be flat roofs, but they could be metal joist roofs or deck 

roofs. We allocated these evenly over the 1999 edition's roof construction categories. 

The fractions of roof types estimated were used to weight the required U-factors from the 

1999 edition for each climate and for each category of building, non-residential, semiheated, and residential. 

The results (shown in the following table) suggest that for rnost non-residential buildings, 

the 1999 edition has more stringent roof U-factor requirements in warm to mild climates 

(significantly so in Knoxville and Los Angeles, moderately so in Orlando, Seattle, and 

Shreveport, and slightly so in Fresno). It is slightly less stringent in the cooler climates of 

Denver, Detroit, and Providence, and is significantly less stringent in Minneapolis and 

Phoenix. Overall, we expect a slight increase in heating energy use and slight decrease in 

cooling energy use for rnost non-residential buildings from these requirements. 

The semi-heated building category in the 1999 edition shows a substantial increase in 

average U-factor for all buildings, which is expected to result in increased energy use due 

to increased heating loads for these buildings. 

A comparison of the requirements for the residential space category in the 1999 edition 

shows a reduction in U-factor (increase in stringency) for all climates except Los Angeles, 

which shows a substantial increase in U-factor (decrease in stringency). 

Overall, it is expected that the changes in U-factor requirements in the 1999 edition will 

result in some increase in heating energy use, primarily as a result of the significant 

changes in requirements for semi-heated spaces. It is expected that it will also result in 

some decrease in cooling energy use in most (but not all climates). 

 6450-01-P COMMENT 18
I Average Roof U-Factor Required I 

1999 Edition 

1989 Non-Res- Semi- ResCity Edition idential Heated idential 

Denver 0.05 1 0.054 0.123 0.045 I 

Detroit 0.053 0.054 0.123 0.045 

Knoxville 0.1 10 0.054 0.149 0.045 I 

Los Angeles 0.100 0.070 0.202 0.200 

Minneapolis 0.045 0.05 1 0.123 0.045 

We have 

1. Negative U-factors indicate decreased stringency 

reflected the above in changes to the draft analysis. 

Change 

1989-1999 

Non-Res' 

1.7. Floors over unconditioned spaces. 

8. Floors Over Unconditioned Spaces. The conclusion to this section, "overall there will 

be a net decrease in energy use under the floor criteria in the 1999 edition" is not clearly 

substantiated by the data presented in the accompanying table (Table 7). While it is true that the 

stringency of wood framed floors in non-residential buildings have increased under the 1999 

standard, the comparative level of stringency is mixed for steel joist and mass floors in nonresidential. Of greater impact, however, is the reduced stringency for semi-heated buildings, 

which account for almost 20 percent of all commercial floorspace. The comparative stringency of 

residential buildings is totally ignored. Without a more thorough analysis it is inappropriate to 

make any definitive conclusions as to the impact of the revisions in the 1999 standard. 

Response: We agree with the comment. We expect semi-heated buildings to primairly 

include warehouse, parking garage, and automobile service type buildings. Unfortunately, 

while we can envision very little semi-heated floor space over unconditioned spaces in 

most semi-heated buildings, we are not aware of reliable data on floor construction in 

buildings, to make a definitive estimate. 

 6450-01-P COMMENT 18
In comparing U-factor requirements for semi-conditioned spaces, wood frame floors are 

clearly more stringent under the 1999 edition. 

For steel framed floors in non-residential spaces, the 1999 edition is approximately 1.5 to 

four times more stringent for moderate to warm climates. They are approximately equal to 

slightly less stringent for the climates of Seattle, Denver, Detroit, and Providence. Finally, 

they are approximately30 percent less stringent for Minneapolis, a cold climate. 

For mass floors, the 1999 edition is less stringent by a factor of approximately two for 

Seattle, Denver, Detroit, Providence, and Minneapolis. It is approximately 45 percent less 

stringent for Knoxville. It is approximately the same for Fresno and Shreveport. It is 

approximately 24 percent more stringent for Los Angeles and Phoenix. Finally, it is likely 

about a factor of two less stringent for Orlando, given a typical U-factor for an 

uninsulated floor. 

We have removed the concl~lsion about the net results from the draft analysis. 

1.8. Opaque wall thermal transmittance. 

9. Opaque Wall Thermal Transmittance There are two factual errors in the first paragraph 

of this section. First, the range of possible U-factors for mass walls depends partially on percent 

fenestration and internal load density, not just thermal mass as stated. Second, mass walls in the 

1999 edition do not generally fall within the range of allowable values in the 1989 edition as 

stated. Non-residential mass walls, weighted by climate and floor space, have an allowable Ufactor of 0.28 in the 1999 standard compared to U- Factors ranging from 0.227 to 0.25 1 in the 

1989 standard. The conclusion of this paragraph, "since buildings in the semi-heated category are 

expected to have relatively low heating loads and no cooling loads, the reduction in stringency is 

expected to have minimal impact" doesn't appear to give full consideration to the size of the 

semi-heated category, which accounts for almost 20 percent of total commercial floor space. The 

last sentence of this section should be revised to read, "Overall, it is expected that the reduced Ufactor requirements for mass walls in the non-residential and semi-heated category will result in 

increased heating energy use over the 90.1 - 1989 mass wall requirements and increased cooling 

energy use over the 90.1 - 1989 requirements for non-residential buildings." 

Response: We agree that the range of possible U-factors for mass walls depends partially 

on percent fenestration and internal load density, not just thermal mass, as stated in the 

comment. We believe that this is obvious from the remainder of the text of this section of 

the draft analysis. However, we have changed the draft analysis to alleviate any 

misunderstanding. 

The draft analysis already states that the 1999 edition is less stringent for non-residential 

spaces. 

 6450-01-P COMMENT 18
We also agree that, overall, it is expected that the reduced U-factor requirements for mass 

walls in the non-residential and semi-heated category will increase heating energy use 

over the 1989 edition's mass wall requirements. We have added that language to the draft 

analysis. 

We do not agree that this produces an increase in cooling energy use. We believe cooling 

losses through the envelope can be important, particularly if a building economizer is not 

installed or operated. 

1.9. Window thermal transmittance and solar heat gain. 

10. Window Thermal Transmittance and Solar Heat Gain. The second paragraph of this 

section uses the phrase "typical levels of internal gains." Without further clarification, this phrase 

is meaningless and calls into question the conclusion "the requirements for window thermal 

transmittance in residential and non-residential buildings are very similar in both editions. It is 

also unclear what is meant by the phrase "marginally more stringent." In the last paragraph in the 

section, after stating "window solar heat gain requirements in the 1999 edition are typically more 

stringent in buildings with lower glazing areas but often less stringent in buildings with higher 

glazing areas" the analysis concludes that "the overall the 1999 edition is more energy efficient in 

reducing solar heat gain in most buildings" (emphasis added). Without quantifying the weighted 

average percent glazing in commercial buildings, there is insufficient data presented to draw that 

conclusion. The sentence should be revised to read in part "the overall the 1999 edition is more 

energy efficient in reducing solar heat gain in most buildings with more than 30 percent glazing." 

Response: We disagree with the conclusion. The levels of internal gains for both the 

wall and window assumptions have been clarified. The phrase, "Marginally more 

stringent in the rest of the country," has been quantified using an average percent change 

range to differentiate it from the cold climates. We have shown the average window 

fraction from the quantitative analysis to support the phrase, "most buildings." Finally, 

the last sentence in the comment is incorrect. It should read "overall the 1999 edition is 

more energy efficient in reducing solar heat gain in most buildings with less than 30 

percent glazing." 

This comment reflects a different opinion than ours on the most appropriate approach to 

the analysis. In the determination, we grouped this comment with comments on the 

subjective nature of the analysis of the envelope section, exit signs, the use of the 

prescriptive compliance path and not the performance paths in the analysis, our 

conclusions on the lighting power exemptions, temperature reset controls, and heating 

equipment. 

1.10. Opaque doors. 

 6450-01-P COMMENT 18
1 1. Opaque Doors. The conclusion to this section could be clarified by revising the last 

sentence to read "However, in individual buildings with a significant number of doors, like 

warehouses, the impact may be significant." 

Response: We agree with the comment if it is changed to read, "some" warehouses. Many 

large warehouses only have a few doors where trucks or trains enter or exit the building 

and unload inside, instead of parking outside the building and unloading through doors. 

We have changed the conclusion accordingly. 

1.1 1. Load calculations and sizing. 

D. Mechanical Equipment and Systems; 1. Load Calculations and Sizing. The omission 

of explicit sizing requirements for HVAC systems while unlikely to have much impact on large 

commercial buildings, which are typically designed by engineering professionals, could have a 

significant impact on smaller commercial buildings, especially design-build facilities. The 

inclusion of explicit maximum safety factors in the 1989 standard recognizes the tendency for 

much larger values to be used by system designers. The exclusion of such factors in the 1999 

standard has the potential for significantly oversized equipment to be specified, resulting in 

operating inefficiency. 

Response: We agree. The exclusion of factors limiting the amount of allowed system 

over sizing in the 1999 standard has the potential for significantly oversized equipment to 

be specified, particularly in smaller buildings. Such over sizing would result in operating 

inefficiency. We have added text to the draft analysis to reflect this. 

1.12. Separate Air Distribution Systems. 

2. Separate Air Distribution Systems. The conclusion to this section indicates that 

differences in the requirements for separate air distribution systems between the 1989 and 1999 

standards could result in a minor reduction in stringency in a limited number of buildings. The 

impact could be significant, however, in mixed use buildings, which are on the rise. 

Response: We disagree. The requirements for separate air distribution systems in the 

1989 edition refer to systems satisfying process applications. This would not impact 

mixed use buildings, such as office and retail combinations which generally do not 

include process applications. We have made no change to the draft analysis in response to 

this comment. 

1.13. Temperature controls. 

3. Temperature Controls. This section concludes "the 1999 edition.. . will limit reheating 

and recooling done by separate systems, which will provide improved efficiency over the 1989 

edition." The partial basis for this claim is that the 1989 standard "explicitly requires a set point 

overlap restriction when the heating and cooling to a zone are controlled by separate thermostats 

 6450-01-P COMMENT 18
within that zone." However, it is hard to understand how this provision is substantially different 

from Section 9.4.3.2.3 in the 1989 standard, which states: 

Where used to control both comfort heating and cooling, zone thermosfatic 

controls shall be capable ofproviding a ternperatzrre range of at least 5 "F within 

which the supply ofheating and cooling energv to the zone is shut offor reduced 

to a minimum. 

Response: We believe that the language in the 1989 edition is ambiguous. In the 1989 

edition it is not clear whether individual thermostats are required to control both heating 

and cooling to a 5-degree Fahrenheit deadband, or whether the space should be 

controlled to provide a 5-degree Fahrenheit deadband. The purpose of the revised 

language in the 1999 edition is to provide clarity. We have added a sentence to the draft 

analysis to point out the ambiguity in the 1989 edition's temperature control wording. 

1.14. Off-hour controls and setback. 

4. Off-Hour Controls and Setback. The second paragraph of this section describes the 

zone isolation requirements in Standard 90.1-1 999, which clearly defines maximum airflow in 

unoccupied areas. Standard 90.1 - 1989 has similar zone isolation requirements, although 

maximum airflow rates are not specified (Section 9.4.4.3). Given the subtle differences between 

the two standards (i.e., implicit vs. explicit requirements) the conclusion that "The 1999 edition 

by requiring maximum setback air volumes has more stringent off-hour requirements" seems to 

be overstating the case. 

Response: We agree. We have revised the textual analysis to read, "The 1999 edition, 

by requiring maximum setback air volun~es, has explicit, and therefore more stringent, offhour requirements." 

1.15. Radiant Heating. 

7. Radiant Heating. This section claims "the requirements in the 1999 edition that radiant 

heating be used on unenclosed spaces such as loading docks without air curtains will save energy 

compared to the use of warm-air systems allowed in the 1989 edition." This statement is factually 

incorrect. The TPS of the 1999 standard explicitly includes unenclosed spaces by defining a 

building as "a structure wholly or partially enclosed within exterior walls." However, the TPS of 

the 1989 standard does not include such spaces, but rather limits coverage to "new buildings 

intended for human occupancy." In addition, the 1989 standard requires "radiant heating systems 

shall be considered in lieu of convection or all-air heating systems to heat areas which experience 

infiltration loads in excess of 2 air changes per hour at design heating conditions." This provision 

would certainly apply to spaces such as unenclosed loading docks. 

Response: We disagree. The comment is internally inconsistent. On one hand it states 

that the title, purpose, and scope of the 1989 edition does not includes such spaces as 

loading docks without air curtains. But in the next sentence, it states that there are 

 6450-01-P COMMENT 18
requirements for such spaces. If the title, purpose, and scope of the 1989 edition is not 

assumed to include unenclosed spaces, then the standard has no requirements for these 

spaces and air heating systems are allowed by default. By specifically including them in 

the title, purpose, and scope and requiring radiant heating systems, the 1999 standard will 

save energy. 

We have revised the draft analysis to explicitly state the above 

1.16. Pipe and duct insulation. 

9. Pipe and Duct Insulation. The first paragraph of this section acknowledges "the 1999 

edition has slightly less stringent pipe insulation requirements than the 1989 edition for most 

building applications," but then concludes that "these differences should have minimal impact." 

This seems like a very unlikely conclusion; especially given the great emphasis placed on pipe 

insulation projects in demand-side management programs nationwide. 

Response: We believe that there are significant energy savings from adding insulation to 

non-insulated piping. Demand side management and other energy programs nationwide 

to encourage adding insulation to existing piping, where insulation is old, failing, or 

absent. However, the marginal net energy savings resulting from differing levels of 

insulation in insulated piping requirements in the 1989 and 1999 editions is expected to 

have minimal impact. 

We have added words to the draft analysis that points out that since the piping is insulated 

under both standards, the incremental reduction in insulation is expected to have minimal 

impact. 

1.17. Completion requirements. 

1 1. Completion Requirements This section discusses the Standard 90.1-1999 

requirements for plans and specifications to include commissioning instructions for heating 

ventilation and air-conditioning systems and concludes that these requirements "have the 

potential to provide long-term energy efficiency beyond what would be expected under 

the.. .I989 edition." However, given the total lack of any long-term enforcement mechanisms in 

the 1999 standard, this conclusion is highly optimistic. 

Response: We used the words, " . . . potential long term energy efficiency" and believe 

the statement is correct. There is a significant amount of literature documenting the 

benefit of cominissioning buildings and there has been a series of nine annual national 

conferences on building commissioning which the Department has sponsored to promote 

building commissioning activities. We believe that ,while over time operations degrade so 

of the initial efficiency gained from commissioning, systems never having operated at 

design efficiency will degrade further than those that have been commissioned. 

 6450-01-P COMMENT 18
1.18. Simultaneous heating and cooling controls. 

12. Simultaneous Heating and Cooling Controls. Both the 1989 and 1999 standards have 

essentially identical text designed to prevent the occurrence of simultaneous heating and cooling. 

While both standards provide commonsense exceptions to this requirement, the 1999 standard 

provides much more detail regarding the possible characterization of the circumstances under 

which the exception would apply. Given the similar intent of the two standards, the conclusion 

that the 1999 standard "should result in significant reduction in building energy use for many 

common multi-zone HVAC system designs" seems to be overstating the case. 

Response: We agree. We have added text to the draft analysis stating that the 1999 

standard provides much more detail regarding the possible characterization of the 

circumstances under which the exception would apply. The Department will remove the 

word "significant" in describing the reduction in energy use. 

1.19. Economizer controls. 

13. Economizer Controls. This section concludes that, in general, 90.1-1 999 attempts to 

provide more economizer standards where economizers are most beneficial, and to not require 

them in climates where they provide less benefit. In our analysis we found that the 1999 standard 

actually increased economizer use. 

Response: We believe our initial statement is correct. It is not clear what is meant in the 

comment by, "... the 1999 standard actually increased economizer use." We suspect that 

the increase in economizer usage, that is referred to, is a result of using different 

assumption than we used. We suspect that the assumptions differed in weighting of 

climates and in assuming a larger fraction of smaller unitary cooling equipment in the 

equipment weighting methodology. The comments do not counter our assessment that, in 

the 1999 edition, economizers are required in locations where they are more beneficial. 

We have made no change in the draft analysis in response to this comment. 

1.20. Temperature reset controls. 

16. Temperature Reset Controls. This section indicates that "1999 edition removes the air 

reset requirements, but addresses simultaneous heating and cooling more directly [than the 1989 

standard] by better limiting the amount of air reheated or recooled" and concludes by stating 

"some minimal degradation in efficiency is expected from removal of the air-side reset 

requirements, but this is likely to be mitigated by the increase in efficiency from requiring reset on 

smaller hydronic systems." Given the apples and oranges nature of these two requirements, there 

is no way to draw this conclusion. 

Response: We disagree. The 1989 edition requires reset of supply air temperatures for 

multiple zone systems. The 1989 edition requires reset of hydronic systems greater than 

600,000 Btu/h. Both air and hydronic system reset requirements are exempted, if it can be 

 6450-01-P COMMENT 18
shown that they increase overall building energy, as might be the case with some designs 

of variable flow hydronic systems. 

While the 1999 edition's reset requirements on the air side were removed, the 

requirements for reset on the water side were extended to more (smaller) systems. Neither 

standard requires reset on variable flow hydronic systems. In practice, for non-variable 

flow systems, the 1999 edition has more stringent reset requirements, due to the water side 

reset requirements. For variable flow systems, the 1989 edition has more stringent 

requirements for air side reset. However, the air supply reset criteria require more water 

to be pumped and therefore there is a tradeoff between pumping energy and chiller 

performance. We have no data to show whether this results in energy savings or greater 

energy cost. (The 90.1 Standing Standards Project Committee was of the belief that the 

benefits of variable flow outweighed the chiller performance savings.) However, more 

reheat energy may be required for these systems, since the air supply temperature is not 

reset. The better language to prevent reheat in the 1999 edition may compensate. For 

clarification we have replaced the word "offset" with the word "mitigate" in the draft 

analysis. 

This comment reflects a different opinion than we hold on the most appropriate approach 

to the analysis. In the determination, we grouped this comment with comments on the 

subjective nature of the analysis of the envelope section, exit signs, the use of the 

prescriptive compliance path and not the performance paths in the analysis, our 

conclusions on the lighting power exemptions, window thermal transmittance and solar 

heat gain, and heating equipment. 

1.21. Hot gas bypass reduction. 

17. Hot Gas Bypass Reduction It would be very difficult to document energy savings 

from this provision. In addition, under the 1999 standard there will be more equipment cycling, 

which could increase maintenance cost and/or reduce equipment life. Reducing energy costs at 

the expense of other owning and operating costs is false economy. 

Response: We disagree. The comment argues that removing the use of hot gas bypasses, 

(an inefficient method of unloading equipment) could increase maintenance cost and 

reduce equipment life. Major manufacturers of cooling equipment have aIready begun 

avoiding the use of hot gas bypasses by providing other and more efficient means of 

equipment unloading. The argument that this will result in increased maintenance cost or 

reduced equipment life is speculative and we believe unfounded. For instance, recent 

conversations with Trane representatives have indicated that hot gas bypass is no longer 

used on large centrifugal chillers from that manufacturer for efficiency reasons. 

We have made no change to the draft analysis in response to this comment. 

 6450-01-P COMMENT 18
1.22. Heating, ventilation and air-conditioning equipment. 

1 8. Heating, Ventilation and Air-conditioning Equipment. The second paragraph in this 

section and the accompanying table (Table 9) indicates that Standard 90.1-1999 will result in a 

5.2 percent full-load efficiency improvement for absorption chillers even though acknowledging 

that the 1989 edition had no efficiency requirement for absorption chiller equipment. This energy 

efficiency improvement credit is based on the minimum criteria established by the 3999 standard 

for double-effect absorption chillers compared to an arbitrary market baseline for comparable 

units. A similar energy efficiency improvement credit of 25 percent is taken for single-effect 

absorption chillers. The implication is that if minimum energy efficiency criteria for absorption 

chillers had been included in the 1989 standard, it would not have exceeded the arbitrary market 

baselines cited. This is clearly only conjecture on the part of the analyst. The last paragraph of 

this section concludes "dZ of these requirements will improve the general efficiency of 

commercial space conditioning products beyond that required in the 1989 edition, and will thus 

contribute to energy savings with the 1999 edition" (emphasis added). This is clearly not the case 

in the following instances: (1) absorption chillers for which there were no minimum criteria in the 

1989 standard, (2) room air conditioners whose minimum efficiency requirements were driven by 

manufacturing standards rather than the 1999 standard, (3) boilers for which there is no change in 

efficiency between the 1989 and 1999 standards, or (4) heat rejection equipment for which there 

were no minimum criteria in the 1989 standard. The tabulated data indicates an estimated fullload efficiency improvement of 10. I percent for room air conditioners. This is taking credit for 

the efficiency improvements mandated by NAECA, which would have been implemented with or 

without the revised standard. The correct value should be 0 percent. In addition, the tabulated 

data includes undefined footnotes for several equipment categories that make it impossible to 

understand the basis of the comparison. 

Response: Where the 1999 edition has equipment efficiency requirements, but the 1989 

edition does not (as in the case with absorption and heat rejection equipment, for 

example), increased energy efficiency occurs unless the requirements are at or below 

common practice. In these cases, we used ASHRAE's assessment of the minimum 

performance of the equipment used in common practice, as a baseline. The 1999 edition 

efficiencies are more stringent than this baseline. When a new piece of equipment is 

added to the standard, it is reasonable to use a market assessment of stringency to predict 

impact. The 1999 edition's requirements for thermal efficiency will remove some boilers 

from the market that currently meet the single 80 percent combustion efficiency 

requirement in the 1989 edition, and have thermal efficiencies of less than 75percent. 

This is particularly true of steam boilers, as was evidenced by the original the Gas 

Appliance Manufacturers Association submittal of steam boiler efficiency used in the 

development of the 1999 edition's requirements. The point regarding room airconditioning equipment is correct, as we point out in paragraph three of the draft analysis. 

However, we have repeated this in the conclusion of the draft analysis. 

This comment reflects a different opinion than ours on the most appropriate approach to 

the analysis. In the determination, we grouped this comment with comments on the 

subjective nature of the analysis of the envelope section, exit signs, the use of the 

 6450-01-P COMMENT 18
prescriptive compliance path and not the performance paths in the analysis, our 

conclusions on the lighting power exemptions, window thermal transmittance and solar 

heat gain, and temperature reset controls. 

1.23. Service water heating equipment efficiency. 

19. Service Water Heating Equipment Efficiency. The second paragraph of this section 

indicates "for electric water heaters greater than 12 kilowatt input, the 1999 edition does appear 

to allow marginally greater standby loss" but concludes "since this product is covered by a 

Federal national manufacturing standard that is more stringent than the requirements of the 1999 

edition and the federal standard preempts state or local regulation, unless a waiver is granted, the 

reduced stringency in the 1999 edition should result in no reduction in efficiency." This 

conclusion overstates the fact as the federal regulations cited apply only to resistance water 

heaters less than or equal to 12 kW and heat pumps less than or equal to 24 amps and 250 volts. 

Response: We disagree with the comment. There are federally mandated equipment 

manufacturing standards for commercial electric resistance water heaters 12 kW and over 

in the Energy Policy and Conservation Act, as amended, and these are the equipment 

categories that are referred to in our comparison cited above. The Federal equipment 

manufacturing standards do not separate out heat pump water heaters less than 12 kW as a 

different class and do not require efficiencies beyond that of electric resistance products 

less than 12 kW. We have changed the language in the draft analysis to make this clear. 

1.24. Conclusion about detailed textual analysis. 

2 1. Conclusion About Detailed Textual Analysis. The predominate factor identified in the 

detailed textual analysis, the inclusion of alterations and renovations to the scope of the 1999 

standard and the exclusion of existing buildings in the 1989 standard, has already been shown to 

be factually incorrect. SSPC 90.1 has previously acknowledged that the 1999 standard does not 

extend the scope of the 1989 standard but merely clarifies the description of how it applies. 

Furthermore, the claiins that the 1999 standard will result in a net positive increase in efficiency 

for the Lighting, Power and Mechanical Equipment and Systems sections is poorly documented 

in many instances and factually incorrect in others. The more accurate conclusion from the textual 

analysis is that there will be no increase from the change in scope and an uncertain impact from 

the other changes. 

Response: We disagree with the comment. The1999 edition specifically applies to 

existing buildings whereas the 1989 edition specifically does not. Nor was there any 

intention by ASHRAE in 1992 to have the 1998 edition apply to existing buildings. At 

that time, ASHRAE had another standard under development for the explicit purpose of 

addressing existing buildings (Standard 100). In the draft analysis, we attempted to 

present a balanced review of the changes in the standard in each of the lighting, power, 

and mechanical sections and, where possible, provide some statement as to the efficiency 

 6450-01-P COMMENT 18
decrease or increase. Any factually incorrect statement brought to our attention has been 

corrected in the draft analysis. 

1.25. Exclusions. 

E. Miscellaneous 1. Exclusions. In addition to the specific areas discussed above, there 

are several energy systems for which minimum criteria were explicitly provided in the 1989 

standard but have been excluded from the 1999 standard. These energy systems include: electric 

power (e.g., transformers), auxiliary systems (e.g., transportation), and energy management 

systems. Although the impact of these exclusions is impossible to quantify, the lack of any 

authority will allow designers to specify inefficient solutions. This will result in higher energy 

consumption under the 1999 standard. 

Response: We disagree with the comment. However, we reviewed the material again 

and identified an area not addressed in the comment. The 1989 edition had requirements 

for the subdivision of electrical power feeders by use category, to facilitate end-use 

metering in buildings with more than 250 kVA connected load. In addition it had 

provisions to check meter the loads of individual tenants with more than 100 kVA of 

connected load. The removal of requirements for subdividing metering loads will make 

check metering and commissioning of these systems more difficult. In doing so, it will 

likely result in some increase in energy consumption. 

The 1989 edition recommended consideration of an energy management system in 

buildings of more than 40,000 square feet. However this is not a requirement in the 1989 

edition. This subject is addressed differently under the 1999 edition (see controls), but it 

is addressed. We expect no change in efficiency due to the change in how it is addressed. 

The 1989 edition optionally suggested that building transformers be selected to optimize 

the combination of no-load, part-load, and full-load losses, and had requirements that an 

annual operating cost calculation be done and saved with the electrical design 

documentation for buildings with total building transformers more than 300 kVA. We do 

not believe that the language for an annual operating cost calculation for large building 

transformer systems actually provided for a comparison over multiple possible system 

designs, and thus its removal is unlikely to have a significant impact on building 

efficiency. 

The 1989 edition had motor efficiency requirements for motors operating more than 500 

hours per year. Such motors are less efficient than Federal manufacturing standards 

enacted in 1992 and thus dropping the requirement will have no impact on building 

efficiency. 

The 1989 edition did not have requirements for transportation systems. Its language only 

suggested that consideration be given to the use of efficiency control devices for such 

systems. Elimination of this suggestion from the 1999 edition is not expected to have an 

 6450-01-P COMMENT 18
impact on energy efficiency. We have made no change in the draft analysis in response to 

this comment. 

This comment also reflects a differing interpretation of transformers, transportation 

systems and energy management systems. In the determination we grouped it with 

comments having to do with differing interpretations of lighting power exemptions, 

lighting that is integral to equipment, and the energy cost budget compliance path. 

1.26. Energy cost budget compliance method. 

2. ECB Requirements. The provisions of the Energy Cost Budget Method in the 1999 

standard are generally less stringent than the comparable Cost Budget Method in the 1989 

standard. While it is anticipated that this approach will be used in a comparably small number of 

buildings, these buildings tend to be Larger facilities and represent a significant portion of the total 

commercial building square footage. This reduced stringency can be expected to result in higher 

energy usage under the 1 999 standard. 

Response: No details have been provided in the comment to justify the statement that the 

provisions of the ECB method are less stringent in the 1999 edition. 

For both editionection provides a whole-building tradeoff methodology to allow 

innovative or unique buildings to comply with the standard. The ECB section requires the 

designer to simulate both a baseline building that complies with the standard and the 

actual design being proposed. The building design is not allowed to have a greater energy 

cost than the baseline building that complies with the standard. Neither edition of the 

standard allows designs to exceed the base standard, and as such, the stringency of the 

ECB method in each edition is roughly equivalent to the stringency that would be 

achieved, if the building complied with the prescriptive requirements of the respective 

editions of the standard. We have reflected this in revisions to the draft analysis. 

This coiment also reflects a different interpretation than ours of the energy cost budget 

compliance path. In the determination we grouped it with comments having to do with 

differing interpretations of lighting power exemptions, lighting which is integral to 

equipment, transformers, transportation systems, and energy management systems. 

1.27. Non-code language. 

3. Non-Code Language. The 1999 standard is written in code language and as a result 

excludes some of the guidance provided in the 1989 standard. Although much of the language in 

the 1989 edition is not enforceable as witten, it provided designers with guidance in 

implementing energy efficient solutions. 

Response: We agree with the observation. Conversely, however, the 1989 edition is 

difficult to design to and enforce for just that reason. 

 6450-01-P COMMENT 18
2. Comments by James A. Ranfone, American Gas Association 

2.1. Department of Energy legislated responsibilities. 

On Aprill2,2000, AGA and the Natural Resources Defense Council (NRDC) wrote 

Assistant Secretary Reicher concerning statutory requirements of DOE to determine whether all 

new energy efficiency measures in ASHRAE 90.1(1999) are technologically feasible and 

economically justified. A copy of this correspondence (Attachment 1 ), including a detailed 

analysis of the relevant statutory language prepared by AGA 's Deputy General Council, is 

attached. AGA maintains its view that, under the Energy Policy Act of 1992,42 U.S.C. Section 

63 1 et seq., it is DOE'S "duty to determine not only whether the revised standard would improve 

energy efficiency in commercial buildings, but also whether all new energy efficiency measures 

are technologically feasible and economically justified." To date, no analysis meeting these 

requirements has been prepared either by ASHRAE or DOE. Until such time as an appropriate 

analysis is prepared, either through modification of the current PNNL analysis or through 

independent analysis, DOE should not complete its determination called for under Section 304 of 

the Energy Conservation and Production Act. 

Response: This is addressed in the determination in the section regarding the workshop 

and comments on the analysis methodology: 

"The statutory language in Section 304(b) states that the Secretary is 

required to make a determination as to whether any successor standard to 

ASHRAE Standard 90.1-1989 will improve energy efficiency. The Secretary must 

publish a notice of this determination in the Federal Register. The language does 

not require that DOE perform an independent economic analysis as part of the 

determination process. As a matter of fact, Section 304(b) omits any reference to 

language concerning economic justification. 

"However, Congress was concerned that the technological feasibility and 

cost effectiveness of the Voluntary Building Energy Codes be considered. Section 

307 clearly requires DOE to participate in the ASHRAE process and to assist in 

determining the cost effectiveness and technical feasibility of the ASHRAE 

standard. It also requires DOE to periodically review the economic basis of the 

voluntary building energy codes and participate in the industry process for review 

and modification, including seeking adoption of all technologically feasible and 

economically justified energy efficiency measures. 

"Unlike Section 307 which specifically includes language concerning 

economic justification, Section 304 omits any reference to economic justification. 

"It is generally presumed that Congress acts intentionally and purposefully where 

it includes particular language in one section of a statute but omits it in another 

section." Bates v. United States, 522 U.S. 23 (1997). Accordingly, the statutory 

scheme cannot be read to require an economic analysis as part of the determination 

process in Section 304(b). 

 6450-01-P COMMENT 18
"The fact that the Section 304 determination process does not require the 

Secretary to perform an economic analysis does not diminish the importance that 

the ASHRAE standards be technologically feasible and economically justified. 

However, it appears that Congress assumed that these concerns would be worked 

out by stakeholders, with DOE participating in the ASHRAE process itself. The 

language of Section 307 clearly delineates DOE as one participant in the process, 

not the ultimate decision maker of the ASHRAE standard or successor revisions. 

Accordingly, for all of these reasons, DOE has determined that it is not 

required to perform an economic analysis as part of its determination process in 

Section 304 of ECPA, as amended. 

We have added this comment as a counterpoint in combining it with comments 2,2.1,4, 

5.1, 8.4, and 10.8. We have also combined this comment with comments 9.2 and 10.2 as 

a counter point on the subject of determination requirements. No change has been made 

to the draft analysis in response to this comment. 

2.2. Peer review of analysis. 

On June 1 1, 1999, AGA wrote Mr. Ron Jamagin of PNNL, Chairman of the ASHRAE 

90.1 Coimittee concerning the lack of peer review of PNNL 's analysis of ASHRAE 90.1 . . . Peer review of the PNNL analysis was promised by Assistant Secretary Reicher but was never 

implemented, even following this correspondence. Comnlents as you have solicited them here do 

not constitute peer review. 

Response: We disagree. We have combined this comment wit11 comment 12. The 

Secretary is not required to solicit comments from interested parties prior to reaching a 

determination under Section 304 of the Energy Conservation and Production Act. The 

sole statutory requirement is that the Secretary's determination be published in the Federal 

Register. During 1999, as a matter of policy to further the determination process, DOE 

solicited comments on the methodology it intended to use in performing its analysis. Prior 

to making its final determination, DOE sought further comments on its application of this 

methodology and the validity of its preliminary conclusions. 

No change has been made to the draft analysis in response to this comment. 

2.3. Market impact of fuel choice. 

On June 1 1, 1999, AGA wrote Mr. Ron Jainagin of PNNL, Chairman of the ASHRAE 

90.1 Committee concerning .... and its failure to include market impacts as they might relate to fuel 

choices and market shares. A copy of this correspondence is provided as Attachment 2..... 

Response: We disagree. The Secretary is not required to analyze market impacts as they 

might relate to fuel choices and market shares prior to reaching a determination under 

Section 304 of the Energy conservation and Production Act. The sole statutory 

 6450-01-P COMMENT 18
requirement is that the Secretary determine whether the revision will improve energy 

efficiency in commercial buildings. 

No change has been made to the draft analysis in response to this comment. 

2.4. Market share of space and water heating equipment. 

The correspondence also points out the use of an erroneous assumption of fixed market 

shares for electric space heating and water heating (10% of the office and retail market) and gas 

space heating and water heating (90% of this market). As pointed out, these assumptions are not 

consistent with the Commercial Building Energy Consumption Survey (CBECS). 

Response: We disagree. The comment refers to the Department's preliminary assessment 

of energy savings done in June 1999. Subsequently the Department did further analysis 

on the total building square footage with electric resistance heat based on CBECS data. 

We concluded that the correct fraction was 19.8 percent. It is this latter figure, based on 

CBECS data, that is used in our draft quantitative analysis of energy savings. Therefore, 

no changes have been made to the draft analysis in response to this comment. 

2.5. Future factors. 

Also, the analysis assumes that market shares for space heating and water heating 

equipment will remain constant in the future, in spite of factors such as inequitable equipment 

efficiency requirements in water heating that impact equipment first cost. 

Response: We disagree. The Secretary is not required to analyze market impacts as they 

inight relate to fuel choices and market shares prior to reaching a determination under 

Section 304 of the Energy Conservation and Production Act. The sole statutory 

requirement is that the Secretary determine whether the revision will improve energy 

efficiency in commercial buildings. 

No change has been made to the draft analysis on the basis of this comment. 

2.6. Energy consumption forecast. 

Furthermore, the PNNL fails to use any published forecasts in predicting energy 

consumption changes over time. Sources such as the GRI Baseline Projection include changes in 

relevant categories of commercial building stock over time. Forecasts such as these are needed in 

the PNNL analysis if future energy consumption and impacts of the 1999 edition are to be 

plausibly estimated. To date, PNNL has shown no attempt to incorporate these comments in its 

analysis. As a result, AGA views the PNNL analysis as incomplete. 

Response: We disagree. The building construction forecast data used in our draft 

quantitative analysis was derived from the Energy Information Administration's National 

 6450-01-P COMMENT 18
Energy Modeling System data sets. We believe that this is ttle most appropriate forecast 

to use for the analysis supporting the determination. No change has been made in the 

draft analysis based on this comment. 

2.7. Interior lighting power requirements. 

From reviewing the PNNL document, it is clear that PNNL is using the lighting power 

densities developed from the "whole building lighting requirements" for both its analysis of the 

1989 and 1999 editions. This method does not set the true limit on the lighting power allowed by 

either the 1989 or 1999 editions. Since the standard is a compendium of minimum requirements, 

it must be assessed on its most lenient (i.e., most energy intensive) interpretation. To do otherwise 

(e.g., to rationalize consumption on "industry practice" or other, non-minimum assumption) 

would not be an evaluation of a minimum standard. In terms of lighting power densities, PNNL 

should have used the "space-by-space" method for assessing energy consumption from lighting. 

Response: We did use the whole building lighting requirements for our draft quantitative 

analysis. We disagree that a space-by-space analysis is appropriate for use in the 

quantitative analysis. See response to 12.8 below. 

2.8. Interior lighting power allowances. 

The impact of use of these alternate lighting assumptions may be critical to DOE'S 

determination. The following is a comparison of total energy consumption estimates conducted 

PNNL and GARD Analytics, Inc. under these alternate assumptions for lighting: 

Response: We combined this comment with comments 12.6 and 11.3. Our review of the 

GARD analysis revealed it had a number of flaws, particularly the space-by-space 

method analysis. Data on the number, type, and size of spaces in buildings is not 

available to reliably rnodel the impact. Assumptions used in the analysis are speculative 

and not based on statistically reliable information. The results of the space-by-space 

Percent Energy Savings, ASHRAE 90.1(1999) vs. ASHRAE 90.1 (1 989) 

Site Energy Savlngs 

Source Samngs 

Cost Savmgs 

PNNL "Whole 

Bwldmng" Method 

3.9% 

5.9% 

6.2O/a 

PNNL "Space-by-Space" 

Method 

Not Available 

Not Available 

Not Available 

GARD "Whole 

Bwldmng" Method 

5% 

8% 

8% 

GARD "Space-bySpace" Method 

0% 

1 Oh 

1% 

 6450-01-P COMMENT 18
analysis can be attributed to incorrect input assumptions about the number, type, and size 

of spaces being representative of the current and future building stock. That is why we did 

not attempt to quantify the differences between the two editions in space-by-space lighting 

criteria. Instead this was addressed in our textual analysis. See the interior lighting 

textual analysis in the determination. 

We have not made any changes to our draft analysis in response to this comment. 

2.9. GTI funded study by GARD Analytics. 

Finally, attached is a copy of the January 29,2001 presentations by Jason Glazer, P.E. of 

GARD Analytics titled "Energy Savings Analysis of the Revisions to ASHRAE Standard 90.1" 

that was presented to the ASHRAE SSPC 90.1 Committee. Also, in December DOE was 

provided with a copy of the completed analysis from Robert Hemphi1 1 of Gas Technology 

Institute who sponsored the study. 

Response: We reviewed the study, agreed with some of the assumptions and approaches 

to the analysis, disagreed with others and recommended revisions. We do not agree with 

the conclusions of this study. Also, see the response to comments 1 1.1 to 1 1.38. 

Relative to the conclusion, we combined this comment with comment 10.4, about weaker 

savings, and as a counter point to comments 5,8,9.3, 10.4, 10.6, and 13. 

 6450-01-P COMMENT 18
-3 

Energy Savings Analysis of the Revision to 

AS- Standard 90.1 

Fwuiing andDirectwn Pmvided &: 

Robert Hemphill - Gas Technology Institute 

Anal& by; 

Jason Glazer, P.E. - GARD Analytics 

PresMfed to: 

ASI3UA.E SSPC 90.1 

me: 

January 29,2001 

Assessment Methodology 

+ Assessment includes: 

10 climates 

16 buildings (large and sd of eight types) 

6 roof and wall cons~on combions 

6 combitions of heating and coolmg equipment 

+ Over 113,000 DOE-2 runs based on detailed building and 

equipment models. 

4 Used DOWCBECS and Census data to weight results for 

national savings. 

2 

Changes 

+ Revised DOE-2 analysis with changes incorporated for: 

r Edueaiion occupant density 

Small weighting factor revisions 

r Small lighting cbangs. 

a Water heater standby lossfefficiency raised 

VAV h curve adjustment 

Hospital and lodging Iighting power and envelope classi~on 

+ New permutation of warehouse using ENVSTD 2.1 heating only. 

+ New pernumion to include 90.1-1989 Addenda F - envelope eriteria 

Ehangc after the Energy Poiioy Act of 1992. 

+ Many editorial improvements to report text 

4 

 6450-01-P COMMENT 18
Conclusions 

Be Due to the revision of ASHRAE Standard 90.1 

No meaningN reduction in source energy use 

No meaningful reduction m end-use cost 

No meaningll reduction in site energy use 

Increase in gas energy use 

Report published in November, 2000 

e Curently available for purchase 

~.gri.o~pub/abstra~ts/gri00~0116.html 

5 

Overall Results 

m 

Total Envelope Mechanical Lighting 

Site Energy Use +3% -2 % -1% 

Site Cost -1 % +2% -2% -1 % 

Electricity Use -2% +2% -1 % 

-2% +I% 

Negative numbers are reductions in energy use and wst 

and positive numbers are increases in energy use and 

cost due to the 1999 revision of ASHRAE Standard 90.1. 

6 

 6450-01-P COMMENT 18
Energy Consumption Variation by 

Climate 

Ndc Isaghdmbmm3driI&h~ mdrpnnmdior dndspI,maY. Ords~;&irfma 

kgcamrmsddmnd~diar~~~~rosndkt. 9 

Scope Comparisons Across Analyses 

hdpia 

%~Iiic 

A&#I 

AM2 

Ale3 

AM 

Sub5a.A 

SubmtE 

%b&C 

Bsildimw iJgb1I.~ 19(WBv.lopt Waa(nlkla BVAC Bvelopa 

lypo Ma&& MI&& PerseaW* Tyw CWlbYdinaI 

All(8typw Muiolunr Prnrriptive TY% IS% 38% 6 6 

2 sizes) Allowed 

~U(8lypar. Wklr ~~cwiptive lw38K 6 6 

21La) Bulld'i.11 

AllR~pa, Maximum Pxsaiptive 8% 1%39% 6 6 

2552s) Albwed 

All(BIyp~, t4ar.k~~. Addendn9E.U 7% lm 3sK 6 6 

Zeuu) Allowed Prr~rriplivo 

All(8typw Maxinum Pollbmur. TM*l%38% 6 6 2 sku) AUo-4 (Wnmkowe) 

AU but Maximum Prcmiptivs TM* 18%,38% 6 6 wusheue Allowed 

BthlV Maximum PxwPlivc 7%, 1% 36% 6 6 OM'% Albwed 

BtI.IU WIok Pn~~iptivt 7% LS%,3sK 6 6 ornm n.i~di.g 

I2 

 6450-01-P COMMENT 18
.7 (Food senice) GARD: 8 (Health care and worship) 

1 wvering 9 climate bins (3 in bin 17) 

: loin 1Ocliibins 

DOE: 2 combinations - Packaged w/Fmacx, Room ACiFumace 

GARD: 6 wmbinatims - adds boilers, chillers, kat pumps 

WE: Building-area method (not always maxhum allowed) 

GARD: Maximum value allowed between space-by-space and 

building area methods 

States Were Revision May Result in 

Shaded states have significant number of &ties that am dassified in the 

four climate bins showing'no change wan increase in site energy, 

source energy or both due to the revision of 90.1. No comparisons are 

made with local energy codes and some states shaded also have a 

number of citiss that are not located in one of the four climate bins. 

See reporl for full details. 

LO 

Gas Consumption Change Versus 

Percent Fenestration 

- h141 

20.0% 

155%. 

5.0% - 

0.m - 

60% 

7- turn 

WWBl#b'.WRabb 11 

- .. (.I .......... * -.-'- .... 

":Z.<:, -- Sbsl-Ok)l -.. 'I. i~aa.- ..- .:... 7 

.. ..., -. b.. .-.. _._& 

---n 

'. .. -.. ..._ .-.. ...* 

..... ...................... '"- -....-.......... ...... 

-canl-D&* 

-!,-Mas-Amc 

-0-Mad-- 

...*.. Mas-MPII 

.....w-Amc 

 6450-01-P COMMENT 18
GasUsc ElahrcUst ~~ SltcEna~y SltcCost 

Al#l WbokbddmgI~ghUng 15% -9% 

Alt#;2 1% more ghg Iff? -2% 

AlL#3 Ad- f 

A18Y4W~W~ lo% 

Subset A No WMhousc 4% 4% 

SUM B OffhlRekd 18% -10% -7% -9% 

-11% -16% 

Energy Impacts Compared to DOE C 

Measm GARD GARD DOE e Whole Butldmg LI* 

Source Energy -1% -8% -S.90? 

S~te Energy 0% -5% -3.9% 

Site Cost -1% -8% -6.2% 

+ GARD with whole building lighting method very similar to 

DOE 

+ GARD Baseline numbers show no memkgful savings 

+ If DOE had used maximum lighting what would results 

have been? 

IS 

Open Questions 

+ Widely missed committee's 25% target. 

Does it maw 

What did not work in the 10 year process leading to 

90.1-991 

4 Should targets be set for the future? 

If they are, how should 90.1 be evaluated? 

Should every addenda be evaluated? When? 

Given compromise, what is the tnre expectation? 

I6 

 6450-01-P COMMENT 18
More Open Questions 

+ Simplified analyses are misleading. 

What tools should be used to perform an evaluation? 

0 What level of detail is enough to capture the differences? 

What assumptions are fair? Maximum reasonable use? 

Should the committee perform the evaluation? 

+ Do people submining change requests need to provide 

energy impacts? 

Does the committee need to provide guidance? 

17 

3. Comments by Jeffrey Johnson, New Buildings Institute 

3.1. Support the Department's determination. This letter is in response to the US 

Department of Energy's (Department) determination regarding the ASHRAEAESNA Standard 

90.1-1999.1 have reviewed the Commercial Buildings Determinations - Explanation of the 

Analysis and Spreadsheet and the 90-lsavingsana1ysis.xls and support the Department's 

determination that ASHRAEAESNA Standard 90.1-99 will improve energy efficiency in 

commercial buildings. 

Response: We have combined this comment with comments 5 and 9.3, concluding that 

the analysis is reasonable and as a counter point to coinments 1 1 all, 12, 12.2, 12.3, 12.4, 

12.6 and 12.7. 

3.2. Opportunities for improving the standard. The Institute also believes that the 

Department should undertake a more thorough analysis and review of building energy efficiency 

measures as prescribed by United States Code, Title 42, Section 6836(b)(2). This section requires 

the Department to: 

(2) seek adoption of all technologically feasible and economically justzjied energy 

eficiency measures; and 

Such an analysis would show that there are substantial opportunities for improving the 

energy efficiency of new buildings that are cost-effective and technologically feasible. In 

particular, it would help West coast and Northeast states who face higher than average electricity 

prices and potential energy supply constraints. The Institute urges the Department to comply with 

this provision of the Code and would encourage the Institute's partners and allies to support the 

Department in pursuing such an effort. 

Response: The comment does not address either the analysis or the subject of the 

determination (will the 1999 edition improve the energy efficiency of commercial 

buildings). The coment is not relevant. 

 6450-01-P COMMENT 18
Appendix A 

Invitation to Comment 

The following is the e-mail invitation to comment on our draft analysis: 

90 1 Determination 

02/07/2001 05:36 PM 

Sent by: Jean Boulin 

To: spielvogel@home.com, KAmrane@ari.org, wpb5@psu.edu, 

arbarfie@southernco.com, dbeaty@dlbassociates.coin, ablack@mcclureeng.com, 

ccottrell@naima.org, rcrane@genlyte.com, jderinger@pacbell.net, 

cfoster@eei.org, rgansler@facstaff.wisc.edu, jgarrigus@marleymeh.com, 

jglazer@gard.com, mgociina@sears.com, dirkandbjg@aol.com, agupta@nrdc.org, 

HalversonM@mail.battelle.org, rharrold@iesna.org, bud@iwaynet.net, 

hingea@aol.com, bhinton@mail.doi. state.nc.us, john.hogan@ci. seattle.wa.us, 

bill.holy@citicorp.com, gchunter@sover.net, Ron.Jarnagin@pnl.gov, 

jdjones@dhcr.state.ny.us, by-sue@earthlink.net, bciorg2@yahoo.com, 

steve.d.kennedy@gpc.com, rburkett@msn.com, michael-lane@msn.com, 

leclairl@marleyct.com, jlindsley@lcilight.com, kluther@fluids.ittind.com, 

rcmathis 1 @aol.com, merle.~ncbride@owenscorning.com, mm-ec@msn.com, 

fmyers@ix.netcom.com, rnickson@nrnhc.org, eobrien@kravco.com, 

bprindle@ase.org, jranfone@aga.org, eric.richman@pnl.gov, 

cramspeck@ashrae.org, jroberts@fanningfaniling.com, 

bob@ross-construction.com, DSaml934@aol.com, peter. simmonds@arup.com, 

sskalko@compuserve.corn, kspain@email.uah.edu, fstanonik@gamanet.org, 

steiner@henryadams.com, brli@worldnet.att.net, glassmarc@compuserve.com, 

minh.tran@piedmontng.com, ctrueman@ampsc.coin, mackair@hotmail.com, 

jvallor@nicor.com, nniatson@sshcinc.com, mweber@ashrae.org, 

pegasus@kuntrynet.com, WlLSONR@RJRT.com, david.winarski@pnl.gov, 

Woodford@ari.org, wajcsff@nu.com, jhw@nrec.com, 

Robert.Hemphill@gastechnology.org, JAJollnson@NewBuildings.org, 

Harold-Crowder@dom.com, SSlote@NEEP.org, dgoldstein@nrdc.org, 

SCoakley@NEEP.org, David.Weitz@bbr.state.ma.us, RAndrews@DOS.State.NY.US 

cc: 

Subject: Analysis for Determination Regarding Standard 90.1 - 1999 

The Energy Conservation and Production Act provides that whenever the 

ANSI/ASHRAE/IESNA Standard 90.1 - 1989, or any successor to that code, is 

revised, the Secretary of Energy (Secretary) must determine whether the 

revised code would improve energy efficiency in commercial buildings. 

The American Society of Heating, Refrigerating and 

Air-Conditioning Engineers (ASHRAE) and the Illuminating Engineering 

Society of North America (IESNA) approved the publication of the 1999 

edition of Energy Standard for Buildings Except Low-rise Residential 

Buildings, in June 1999. After acting on several appeals, the 1999 

 6450-01-P COMMENT 18
edition was published in February 2000. 

The Standard was developed under American National Standards 

Institute approved consensus standard procedures. The American Society of 

Heating Refrigerating and Air-Conditioning Engineers submitted the 

standard to the American National Standards Institute (ANSI) for 

designation as an approved ANSI standard. In December 2000, the 1999 

edition of Standard 90.1 was approved as an American National Standard. 

DOE has performed both a quantitative analysis of the likely 

impacts of the revised code on the energy efficiency of seven categories 

of new commercial buildings compared to the 1989 edition, and a 

non-quantitative assessment of the comparative stringency of those 

elements of the revised code that could not be analyzed quantitatively. 

The quantitative analysis concluded that the 1999 revision of the 

code would likely reduce the source energy consulnption of new commercial 

buildings by approximately 5.9 percent. Site energy savings were 

estimated to be approximately 3.9 percent. 

The comparative assessment of those elements of the 1989 and 1999 

revised codes that could not be quantitatively analyzed also concluded 

that the 1999 standard would increase energy efficiency. The dominant 

factor in this comparative analysis is the 1999 editioas inclusion of 

alterations and renovations to existing buildings. If the value of 

annual investment in building alterations and renovations is a good 

indicator of their impact on energy use, then the expansion of this code 

to existing buildings could produce nearly 50% more savings than if it 

were applied to new buildings alone. The comparative analysis also 

concluded that the non-quantifiable changes affecting Lighting and Power, 

and Mechanical Equipment and Systems would also increase overall 

efficiency, although the changes to the Envelope requirements would reduce 

efficiency slightly. 

Together, these analyses appear to indicate that the revised code 

will improve the energy efficiency of commercial buildings. 

Request for Comment 

The Secretary is not required to solicit comments from interested 

parties prior to reaching a determination under Section 304 of the Energy 

Conservation and Production Act. The sole statutory requirement is that 

the Secretary& determination be published in the Federal Register. 

During 1999, as a matter of policy to further the determination process, 

DOE solicited comments on the methodology it intended to use in performing 

its analysis. Prior to making its final determination, DOE is seeking 

further comments on its application of this methodology and the validity 

of its preliminary conclusions. 

Comments received at: 

 6450-01-P COMMENT 18
http://www.eren. doe. gov/buildings/codes-standards/buildingsdnati 

ons . htrnl 

by March 9, 2001, will be considered in making the final determination. 

The analyses are also located on the web at: 

http://www.eren. doe.gov~%uildings/codes~standards/buildings/co~n~deteminati 

ons .html 

Thank you for your interest in buildings energy efficiency and 

particularly building energy codes. 

Jean J. Boulin 

Office of Building Technical Assistance 

U.S. Department of Energy 

Reply to: 90 1 .Determination@EE.DOE.gov 

 6450-01-P COMMENT 18
Appendix B 

Web Site Invitation to Comments 

The following is the web site invitation to comment and the input screens posted on our web site: 

BTS - Building Enagy Codes "Detailed Textual Analysis Comment Fonn" httpJhuww.eren.doe.~uildin&Eodes...&~uildin&~-~-~m~.h~1 

Detailed Textual Analysis Comment Form 

During 1999, as a matter of policy to further the determination 

use in performing its analysis. Prior to making its final 

etermination, DOE is seeking further comments on its 

1,-1 ----.-A Lclear ,---,-.-- Information i 

I of2 10117R001 1 :59 PM 

C:"fEMP\n.notes.&ta\-1(w187s5@, February 8,2002 -68- 

 6450-01-P COMMENT 18