2010-07-14 Comment questioning several points in the proposed standard

1.Title only includes “NEW FEDERAL BUILDINGS” however the document also includes “Replacement Buildings” and “Major Renovations”. Clarify. 2.It is unclear if sustainable design principles are to be applied whether or not they are “life-cycle cost-effective”. Clarify. 3.“Replacement Buildings” needs to be defined. 4.Section II.A.2 indicates that the “indoor environmental quality requirements” are mandatory for new Federal buildings or major renovation design. Some major renovations do not include “indoor environmental quality. Clarify. 5.Section II.A.3 defines “Major Renovation” however the document is titled “Energy Efficiency and Sustainable Design Standards for New Federal Buildings”. Clarify. 6.Section II.A.3 defines a “Major Renovation” as “any renovation that exceeds 25 percent of the replacement value of the building”. Are all Federal Agencies required to adopt this 25% threshold? 7.Section II.C indicates that ASHRAE 189.1P will be adopted into Federal Building designs. Verfiy and Clarify. 8.Section II.C.2 indicates “energy consumption at least 30 percent below that of the Standard 90.1-2004 or the 2004 IEEC. The latest version of ASHRAE 90.1 is 2007. Has this version been adopted as minimum energy requirements? Clarify. 9.Section II.C.4 – The proposed rule should identify a standard to address moisture control. 10.Section II.C.5 “instructs agencies to not use ozone depleting compounds if an environmentally preferable material is available”. These are available at a higher cost. Is the intent to increase the cost of all projects?