2010-07-27 Comment suggesting that alternative paths for sustainable design compliance be considered

These comments are offered on the basis of lessons from developing and adopting sustainable design standards for the Stat of Iowa. They are not intended to advocate for a point of view and do not represent an official position of the Iowa Department of Public Safety. It might be helpful to consider compliance with a specific code or standard, such as the International Green Construction Code published by the International Code Council or ASHRAE 189, published by the American Society of Heating, Refrigeration and Air Conditioning Engineers, as an alternate path to achieving compliance with the requirements of the proposed regulations, for commercial and high rise residential construction. For low rise residential construction, compliance with the National Green Building Standard could be offered as an alternative. This would relieve agencies which wished to do so of having to interpret the various performance criteria laid out in the proposed regulations and would be likely to enable coordination with design professionals in the private sector when needed. It also may be advisable to consider achievement of specific levels of certification in the LEED program of the US Green Building Council or the Green Globes program as demonstrating compliance with the requirements of the proposed regulations. I am NOT suggesting deletion of the performance requirements specified in the proposed regulations, only that alternative paths for compliance be considered.