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

Open Discussion (Panel 5)

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?

Issue 14: How can improved lighting and zero net energy goals by achieved while improving health care?

Comment by Kurt Knight: [As an] initial goal at VA, we stipulate some energy lighting criteria, but we’re not willing at this time to go to that as a significant issue. Again, we try to do it in a holistic way. We have some of our standards relative to lighting that we think are appropriate for whatever function that we’re doing; it’s different needs for different functions. And that’s the minimum.

So when they do their energy analysis, they can’t go below those minimums, which are not necessarily as low as some suggestions around here. I’d have to look at them specifically. I’m not an expert in that area. But we are establishing them on some lighting.

Question by Jim Woods: So you have lighting minimums?

Response by Kurt Knight: Right. But we still demand that the AE design the building holistically to meet the 30 percent. In health care that’s a challenge because it’s a 24/7 operation. It’s entirely different than an office building. We’ve raised that up the flagpole numerous times and nobody’s – at least in the regulatory area – seems to care. Or they’re simply not doing anything.

So I think from our perspective, yes, we’re going to establish some standard relative to a wide variety. Now have we done that well in low vision area? I would say no. We would probably need to do some work on what should those standards be in a low vision area, in certain types of areas. Our community living center we’re doing – (inaudible) – but -- and by still demanding 30 percent. Now that 30 percent’s going up.

Question by Tom Williams: Did you see the new FEMP standard (a white paper) that came out last week? I can’t believe this: fifty percent [energy] reduction requirement in large hospitals.

Issue 15: How can the potential conflict between the goals of zero net energy and accessibility for low vision persons be resolved?

Question by Jim Woods: Marsha, from your standpoint, from the accessibility perspective, what can we do about this potential conflict?

Response from Marsha Mazz: I don’t know yet. In regard to some of the concerns about involving the [accessibility] community, absolutely we have to. And I’ve already sent Eunice a contact for someone who certainly advocates with NFPA on stairway design issues, including lighting.

But we do have to work together with the competing interests, and if we don’t, we are going to be spinning our wheels. And they’re much bigger and much stronger than we are. They have far more influence than we have. And whenever we attempt to establish a standard – and I’ve said it 100 times already; I’ll just say it one more time – whenever we attempt to establish a standard that in any way impinges on the directions that those competing interests want to go in, we’re challenged on the basis of our support for that standard.

We are, I think, in the accessibility world, more and more being held to higher standards than the codes developers typically.

Question by Jim Woods: How about the responses [by the code developers]?

Response by Marsha Mazz: Just spend five minutes with me and the National Association of Homebuilders and you’ll see that. They demand substantiation for accessibility criteria when their own substantiation for what they want to do is [based on] opinion. And [their] opinion, seems to carry the day until you want to bring forward accessibility criteria.

Comment by Tom Williams: One of the things that I see happening is that there is no accommodation to build functional requirements throughout. And Kurt, you talked about the demands on hospitals and health care facilities. What I’m almost certain is going to be the wave of the future is finding ways of creating less efficient facilities by decentralizing, in order to reduce the energy consumption in a hospital, for example, is to move out services that are high-energy demand into new facilities that start from scratch. Although these requirements may be stringent, at least it’s a way of addressing it.

What it costs us in other energy consumption issues – travel between them, general efficiency of actually providing the service, and so on, is going to go by the wayside. My suspicion is that Congress’ rationale, other than looking good, is to inspire research into new products and materials that will provide or allow us to produce facilities that can respond to those reductions. I think the timeline is probably unrealistic, but that’s what I think is probably their justification for coming up with what appear to be some unreasonable requests.

I see a whole new way of providing healthcare services, not only for the VA but for others in areas where high energy consumption is required just to provide the service.

Response by [Participant]: Interestingly enough, the latest executive order on greenhouse gas reduction requires trying to calculate travel costs associated [with the] separate facilities. The environmental impact of car travel, as well as flying to different sites for staff, or paying people to come in and design projects, all that supposedly eventually will be tracked. How much environmental impact or greenhouse gas consumption that is.

Response by [Participant]: And then you have the low-vision consumer who has to get there with no transportation.

Issue 16: What environmental and perceptual data on artificial/electric lighting are available from buildings with low vision occupants?

Question by Jim Woods: I do have one more question for Eunice. Is this [RP 28-07 ANSI/IES Standard: Lighting and the Visual Environment for Senior Living] based on some hard data research that was done?

Response by Eunice Noell-Waggoner. Right.

Question by [Participant]: So when somebody comes to you and says, “Show me the study,” that’s the mantra, “show me the study, where is the study,” you can point back –

Response by Eunice Noell-Waggoner. Well, I can say, based on what younger people may need, what the median [values are]. Dr. Allen Lewis – I don’t know if you’re familiar with him – he was on the committee that helped develop it. So we had a lot of experts.

Response by Jeanne Halloin: [The draft standard] had to be reviewed by the technical committee, by us and then rewritten, and it had to be reviewed by the board, and a lot of times we had to substantiate things or take them out. So it went through a lot, and that was before it went through ANSI reviews. So it went through a lot of reviews, which is why it takes that long.

Response by Robert Dupuy: But even so, we have people who, looking at that document, tell us that there’s not enough scientific evidence that low-vision people need more light.

Response by [Participant]: From a federal perspective, there’s a federal law that says we’re supposed to use national standards where appropriate for our needs. So an ANSI standard means that they [are to be used] where we feel appropriate. And because it’s there, it’s a federal law that says we should be adopting those types of standards.

Response by [Participant]: There are lots of people who, for monetary reasons, disagree with that document.

Issue 17: What design guidance on artificial/electric lighting for low vision persons can be provided in the short term?

Question by [Participant]: The other question I have is: [are there state chapters of the IES]?

Response by Robert Dupuy: Extrapolating from my need, the staff at my state organization [of IES] is monitoring stuff like a hawk, anything that’s coming up that might potentially impact our profession. I mean, they’re on this; they’re lobbying, so on and so forth. I mean, you have state associations or state providers that can look for this stuff, like this little classified here. Or they [are] linked in so that the rule-makers in the state government, know their contact at IES and say, “Hey, let’s take a look at this.”

Response by Jeanne Halloin: Right. What’s happening right now relative to ASHRAE 90.1 is that we got a hold of them and we said, “Look, right now lighting for care facilities is exempt from the energy code because we’re asking for higher light levels than typically you would find in an office environment. And so when they started ratcheting down the energy, they snuck it in there that [health care facilities] were exempt.

Now we have people who are trying to light the spaces with incandescent light because it’s more residential. That’s not where we wanted to go with it. So we’ve got to head those guys off at the pass, and so ASHRAE has said, “Look, we want to establish appropriate lighting power density for older people with partial sight.” So they are going to be meeting the light levels required in this, and then they’ve got probably 25 different facilities that they’re looking at that are well designed lighting-wise for this population group. So they’re going to establish an appropriately higher density [LPD] for senior care.

But the very person that took that on and was willing to do it [for health care] says, “But I can’t be doing that for the office environment because it’s like – they’d just be throwing it all away.” But because we have a restricted population group in the senior care facilities, they’re willing to do it for them.

Comment by Vijay Gupta: I wanted to say something on the low vision lighting level. From my experience, not including the recently experienced conditions, has been bad. But earlier, five years ago, the best time for lighting [for me was] outside dusk time, before sunrise or after sunset. Or not after sunset but close to sunset, that’s the outside best lighting, gives the best contrast. But inside, the contrast in here today is a lot better for me than it was yesterday. I think because lighting levels have been dimmed. But I don’t know what candlepower this is.

Question by Jim Woods: I’d like to [hear opinions] around the table: How good is the correlation between illumination level or luminance and power density?

Response by Jeanne Halloin: There’s not a good correlation, because it’s again, it’s still related to the three-dimensional qualities of the space, the finishes in the space.

Question by Jim Woods: So how can ASHRAE make these changes in LPDs if they don’t know what the consequence is going to be with regard to illumination?

Response by Jeanne Halloin: That’s one reason why you have to get in really early [during the design process] because if they have dark flooring or dark walls, there’s no way you’re going to get there [i.e., lighting levels for the assigned LPDs]. So what you have to do is get into the project really early and start telling them that we need light reflectance values on all the large spaces. So that’s why a lot of recommendations that you hear lighting people say for low vision people, but they’re really the only way we can get the light levels up. You have to actually change things in the building itself.

Comment and Question by Jim Woods: Let me push on a little bit. Everybody’s been talking about 30 percent below ASHRAE. I’ve played this game plenty of times. I can make that ASHRAE number go about anywhere I want it to go so I can get 30 percent below my “baseline design.”’ I can do that. So I think what you’re saying, Jeanne, is if we get in early in the design process, you can influence what the lighting level is for the baseline ASHRAE design, because now you have a level that includes the power density level on the base.

So the baseline ASHRAE number would also reflect the illumination that’s necessary for low vision or for other aspects. Is that kind of what you were thinking about?

Response by Jeanne Halloin: If you get in on it early enough, you can do better in the design process. Yeah, and early in the design process, not the building. Early in the design process you can affect the power density.

Comment by [Participant]: Lighting is often an afterthought. It’s not part of the initial [project budget] breakdown.