Proceedings of: Workshop on Improving Building Design for Persons with Low Vision

Issue 13: How can energy codes and LEED™ “Points” be made compatible with lighting design criteria that accommodate low vision persons?

Comment and Question by Greg Knoop: It’s my experience that we program buildings and lighting levels according to spaces, but we don’t have a program transition. So that space just outside that last door could be programmed with many times the amount of light level that this space is, or vice versa.

Is it possible to start to program defined transition between spaces? Is that realistic, are you seeing that in any design, or is that simply good design practices and so therefore we should write the transitions into the code?

Response by Mary Ann Hay: It’s good design practice. Unfortunately right now [codes are] causing some limitations on addressing transitional areas. A lot of transitional areas are public spaces or circulation areas, and the energy codes are restricting you to half a watt a square foot, so it’s very restrictive in terms of light levels that you can provide in entry areas and in transitional corridors. The energy code is creating a tremendous challenge in doing that.

Comment by Richard Dupuy: I think the energy codes view that as superfluous lighting and you don’t need that. It’s art and it doesn’t serve use of the space. So that’s why you see the lowering of lighting levels in corridors and lobbies, because they’re not important, when in fact it’s just the opposite. So we are restricted by the code to do some things.

Now you can trade off when you’re doing the code. You can take lots from over here and put it over here, and we do that as much as we can. But there’s definitely a limit as to how far you can go.

Response by Mary Ann Hay: You’re compromising someplace else.

Comment by Richard Dupuy: Right. I mean, the code even deals with lighting levels in mechanical spaces [safety issue]. Those spaces are infrequently used and, in Oregon you have to have controls - like occupancy-sensors - so when someone leaves, the lights do go off. But why would you have so many watts per square foot specifically for those storage rooms, things like that? It just doesn’t make sense.

Response by Mary Ann Hay: The danger is that they’ll realize the stupidity of offering those watts per square foot in those spaces and eliminate them without adding back –

Comment by Richard Dupuy: The [new] Oregon code goes into effect tomorrow. Last week I was contacted by the Oregon Department of Energy talking about the 2012 code, which they are already writing. I go, “But the new code hasn’t even started!” They go, “But yeah, but we have to lower those numbers. Now what do you think, 10 percent? What can you do?”

Question by [Participant]: Just pull it out of the air?

Response by Richard Dupuy: Exactly.

Comment by Mary Ann Hay: It goes up for public review. But first of all, you have to be tuned into the fact that it even went out for public review.

Question by [Participant]: There’s no notice?

Response by Mary Ann Hay: Yeah, there’s no [industry] notice. You have to constantly check the [public] notices.

Comment by Richard Dupuy: But if it was in the classifieds, [it was a] little tiny advertisement. Fortunately for me, a person who used to work in my office went to the Department of Energy and so he calls me and he goes like, “This doesn’t make sense to me but what do you think?” But generally speaking I think across the country, codes are written inside a room like this. There’s no consultation.

Comment by [Participant]: This is the same with federal government agencies. I mean, I’ve gone to meetings with staffers up on the Hill, who said, “Okay, how far can you go with the numbers?” I mean, that’s the mindset, at least it passed the House. About eight associations got together and in that meeting said, “Here are some things you can do that don’t deal with numbers,” one of which was to require that the engineers within federal buildings, GSA – most of them are contract [personnel] except for VA – had some required certification [to demonstrate that] they at least know how to operate buildings. And that piece passed through.

But there’s a range of things that they can do, including we tried to get them to require, in legislation, POEs at the buildings. That didn’t make it; their mindset is either LEED™ Certification or reduce the numbers.

Comment by Jim Woods: To a great extent, the Illuminating Engineering Society is silent about this issue. I’ve watched the evolution of ASHRAE Standard 90 since its inception in 1975. Yes, the first version of the Standard 90 was 1975. And it evolved in ‘80 and ‘89, ‘99, 2004, 2007 and 2010. IES came into the picture I think in 1989. What really bothers me in Standard 90 is that there are no [illumination requirements].

Question by [Participant]: Illuminating is part of the ASHRAE [90.1] Standard, right?

Responses by [five Participants] No. The [Lighting Power Densities] are part of the Standard. But lighting and illumination [are] not [in the] Standard 90.

Comment by [Participant]. But Standard 90 is the one that’s driving [the energy codes].

Response by [three Participants]: DOE is driving it, not ASHRAE. They’re using ASHRAE’s standard. Right. They’re writing the standard.

Comment by [Participant]. There has to be far more input [on] the illumination issue in the ASHRAE process: ASHRAE 90.1 [and] ASHRAE 189.1, which is becoming the standard for all other codes.

Comment by Jim Woods: At least 189.1 is addressing illumination. Not well. I don’t know if you’ve [evaluated] 189 or not. It’s scary because it basically says that your energy consumption has to be reduced 30 percent below 90.1; your ventilation has to be at least 15 percent above ASHRAE Standard 62.1, and it varies from ASHRAE Standard 55, so there are inherent conflicts.

Comment by [Participant]: As far as involvement, that’s where there needs to be some involvement by IES.

Responses by [three Participants]. That’s changed. There are more IES representatives now involved in the ASHRAE process, but it’s still a small voice. Yes. So we need to get lighting people involved into that decision-making process. A lot of the IES members are involved in that [process].

Response by Jim Woods. Three or four years from now ASHRAE Standard 189.1, or some similar version, is going to be the standard that government agencies use for design and construction. I mean, the agencies are rapidly moving in that direction.

Comment and Question by [Participant]. [In] the LEED™ point system, usually about a third of the points are on energy, [approximately] 29 available points. [For] the indoor environmental quality [category], are there any points that are available for lighting quality?

Responses by [four Participants]. [Yes, for] controllability. That only [affects] energy. There’s nothing about improving the quality of light. So LEED does not address that aspect. Maybe this is another component that needs to be brought in as we move forward. Well, it seems like this whole standard is built around energy.

Comment by [Participant]. In my humble opinion it’s driven from DOE, [whose] purpose to is to reduce energy, which it probably is doing very well. That’s what it’s supposed to do, so it’s driving energy. And I think on the environment –

Comment by Mary Ann Hay: What they really should be looking at is [energy] consumption, not just connected load. In other words, you should be given latitude of providing appropriate levels of light if they’re controlled appropriately, so that you’re really controlling the consumption [by] taking advantage of daylight opportunity, not having lighting on when a space is not occupied, and looking at the whole building model and how it works.

Response by [Participant]: So it’s like demand.

Response by [Participant]: That would be another way of dealing with it. The state of California is looking at that as a possible way of controlling energy use. So the building would be metered, and you know, if you use more energy, you pay for it and then that sort of self-regulates back down to not having controls. That seems to be a more fair way of dealing with the energy thing instead of always talking about how many watts and LPDs and all that stuff.

Response by [Participant]: I remember years ago when we were looking at a federal courthouse in Sacramento, and it was just about the time that the rolling blackouts were starting in California. Our federal building was lit up outside like the 4th of July, and with rolling blackouts, that’s what we were doing. The building managers were trying to get the courthouse judges to accept half-lamping fluorescent lighting in their areas of the courthouse. And the chief judge absolutely said no. He wouldn’t even consider halflamping in lighting in that area of the courthouse. How can [the federal government] impose these restrictions on people and then not practice itself?

Comment by Kurt Knight: Five years ago is entirely different than what you’re doing now. So we really can’t think much about what we used to do. First of all, there’s a 30 percent incident. We don’t give specifics. We say, you, designer, build us a building at 30 percent better than ASHRAE. I mean, that’s what the law says. But we don’t stipulate that it has to be lighting, it has to be this. It’s a holistic approach of trying to achieve the 30 percent. Use design in an integrated way to do that.

Another thing is that commissioning is now required on all projects. Retro-commissioning is now required on all projects. Metering is required on all projects. So you’ll not only get the initial design, it’s going to be metered to see if it does perform in accordance with its [energy targets]. Again, this is all going to be driving on the energy side. You can’t measure lighting controls. You can put a meter on the electric bills, hook up and say, “You’re using X number of BTUs,” which is going to say there’s demands on all existing buildings to reduce energy usage 3 percent every year to a maximum 15 percent. That’s what the law is now.

There’s a drive to reducing old building energy, there’s a drive to reduce new building energy. There’s going to be metering in those buildings to see if they’re compliant, and the records on the medical centers at VA are not going to sit back and say, “Wow, we really don’t want to do this because we didn’t meet our energy goals.” VA’s policy secretary says, “We’re going to meet these goals, and by God you’d better meet it or you’re organizationally not going to go very far.”

Comment by Jim Woods (as Moderator): Let me bring it back. We’ve got about five minutes max, so I think I want to bring it back to low vision, of designing for people with low vision. We’ve pushed on this energy thing pretty hard. I want to frame it in two ways.

One is, as we move forward with this zero net energy and we begin to look at how many people with disabilities of any kind are in the buildings. I would like to have Marsha lead a little bit of discussion on this.

The other related issue, Kurt, I’d like to have you address, and this is in health care, as we begin to look at this. I don’t know if you want to call it healthcare disabilities or not. As we try to improve health care, improve lighting, as we look at the zero net energy, how do we deal with this issue as we move forward?