Final Fortnight

The deadline for submitting comments about the proposed life-threatening Addendum ‘am’ to ASHRAE 189.1 is two weeks from today. Your
help is needed. It won’t take more than 30 minutes and it could end a dangerous threat to your business.

There are few actions you can take that are more important than filing comments against the onerous proposal that threatens reduce the amount of glass that can be used in a building by up to 25 percent. There has been a fair amount of commentary about the proposed Addendum over the past few weeks. It is significant to note that those in this industry of varied, diverse and vocal opinion-givers have all come together to work against this very flawed proposal that will have far-reaching ill effects for our industry if passed.

This standard is an ANSI Standard, meaning it is developed under a protocol that the independent American National Standards Institute (ANSI) deems to be fair, open, balanced and transparent. No non-supportive comment can be ignored or brushed aside; they must all be addressed by the committee in order for a “consensus” to be achieved or the addendum will not become part of the standard. This is why it is so important that you file comments pointing out the flaws in the proposal.

If there is a silver lining in this whole very bizarre proposed addendum, it is that our industry has been united in its opposition to it. Everyone knows how bad the consequences will be if passed and has rallied accordingly.

I had the good fortune to speak with Guardian’s president, Scott Thomsen, about the issue a few days back. “We are doing everything we can to raise awareness about this addendum,” he said. “We are communicating constantly with our customers and our network of certified fabricators and urging them to comment. It’s crucial.”

He has also expanded outreach about this addendum to architects, designers and others in the building community. He says it is gratifying to see that no one is too interested in giving up light and a view and the other advantages of glass.

Thomsen added that some who read the addendum might falsely believe it won’t affect them. “At first glance, this will seem like it will have a negligible effect on local retailers and on contract glaziers. But the opposite will, in fact, be true. These groups won’t see it [the negative impact] right away but they will begin to feel it in 12 months and by 18 months it will have taken a heavy toll. That is part of the reason we are so concerned.”

Many other manufacturers and fabricators have also been urging action. Michael L. Rupert, PPG’s director of technical services and product development for flat glass, issued an excellent background paper to all its construction stakeholders. “We believe this proposal is flawed,” said Rupert, “as it will not only have a negative impact to our industry and reduce design options, but it also runs counter to a key pillar of the green movement, and that is occupant well-being.” Rupert urges stakeholders to file comments. “Your serious consideration to this call to action is greatly appreciated,” he said.

The point man for this whole issue is Tom Culp of BirchPoint Consulting, who has been spearheading the efforts for the glass industry through the Glass Association of North America. He has issued a position paper that explains the major flaws with the addendum. They are summarized below and followed by step-by-step instructions on how you can comment on the addendum. The proposal is flawed in many ways. Chief among them the proposal:

  1.  Ignores the positive impact windows and views have on human beings;
  2. Doesn’t account for the potential harm to building performance and occupants caused by reducing window area and views by 25 percent;
  3. Is oversimplified and does not consider the many aspects of building design;
  4. Hinders design flexibility for architects;
  5. Does not include any technical analysis that justifies a 25-percent reduction in window area;
  6. Conflicts with LEED and other green standards;
  7. Will have a negative financial and economic impact on building owners; and
  8. Ignores the fact that building owners and occupants like expansive window views.

Here is how to comment on the Addendum:

How to comment on addendum “am”,
the ASHRAE 189.1 proposal to reduce window area
(prepared by Thomas Culp)

Note:  Comments MUST be posted by Monday, June 17.

1)  First, prepare your comments in a Word document.

Later you will cut and paste your comments into the ASHRAE comment website.

Some issues you can raise are included later, but write your comments in your own way and add any other points you feel are important.  Individual comments are more effective than many people submitting the same comment.

Also, please focus your comments on the specific proposal to reduce glazing area, not ASHRAE or the committee.  Feel free to criticize the proposal as much as you like, but it will not help us to criticize ASHRAE or certain members of the committee.

2)  Go to the ASHRAE comment website:
https://www.ashrae.org/standards-research–technology/public-review-drafts

3)  Click on the “Click Here” button.

4) Scroll toward the bottom under the heading “45-Day Public Review Period from May 3, 2013 – Jun 17, 2013,” and look for the second item, which starts out “BSR/ASHRAE/USGBC/IES Addendum am …”

You may click on the link with the name of the document if you want to see another copy of the proposal (same as what I sent out previously).

5) Click on the “Comments” link to the left of the addendum “am” name.

6) Log in as a new commenter using the link at the bottom, or if you have previously registered, log in using your email and password. 

7) On the next screen, make sure it lists the document at the top as addendum “am” them click the “New Comment” button. 

8) Type in your name exactly as shown and hit the “I Agree” button.

9) Now you are finally at the comment screen.

a) Fill out your affiliation or company.

b) Comment title:  just give your comment a short title.

(e.g. “Withdraw addendum am” or “Concerns with addendum am” or “Proposal fails to address human impacts” or something about your comments)

c) Comment Type:  choose “Substantive”

d) Section / Subsection Type:  choose “Sub-clause”

e) Section / Subsection Number:  type “7.4.2.4”

f) Supportive: select “NO”  ß This is very important.  If you accidentally choose “yes,” your comment will not be addressed by the committee and may not even be read.

g) Attachments: you may attach a letter with your comments if you wish, but you don’t have to.  You can just enter your comments into the next two fields. 

If you do submit your comments as an attached letter, make sure to also include your specific requested action along with your comments – in this case, “withdraw addendum am.”

h) Comment (Proposed Text):  This is not your body of comments, but what you are proposing.  Important – you must propose a specific action or change.  In this case, simply type “Withdraw addendum am.”

i) Substantiating Statements:  This is where you paste your main comments. 

If your comments are particularly long with multiple topics, you can also break it into parts and submit each part as a separate comment, if you want.

j) Click the “Submit” button

If you have any questions, please feel free to contact Mr. Culp at culp@birchpointconsulting.com or 608/788-8415.  He will gladly help walk you through the process.

2 Responses to “Final Fortnight”

  1. Rick Leserman says:

    Debrah,

    Sorry to be the contrarian here, but won’t the beauty of glass far outweigh the desire to use less glass and use more brick? Shouldn’t the consumer be the one who decides on what he wants to pay for? This coming from a life long Democrat!

    Most of the folks you are citing here I bet would agree with my assessment; however, it will hit them in the pocketbook so they are fighting this proposal aggressively. My 1 cent of opinion.

  2. Deb Levy says:

    That’s the point Rick. The consumer won’t have this choice because the amount of glass you can use will be limited by the codes. This addendum, if passed, reduces the amount of allowable glass on the building. Period. It reduces the choices the end user and consumer has for aesthetic or other reasons.

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