ID#695 made on
EQc3.2 - Construction IAQ management plan - after construction
LEED BD+C: New Construction, LEED O+M: Existing Buildings, LEED ID+C: Commercial Interiors, LEED BD+C: Core and Shell, LEED BD+C: Schools
This request is an appeal to a CIR submitted for Hillsboro Civic Center. We are requesting the use of dynamic air cleaners, utilizing ultra-violet germicidal irradiation (UVGI), as equivalent to MERV...
This request is an appeal to a CIR submitted for Hillsboro Civic Center. We are requesting the use of dynamic air cleaners, utilizing ultra-violet germicidal irradiation (UVGI), as equivalent to MERV 13 static filtration media. 1.) The basis for rejection seems to rest solely on the fact that LEED references ASHRAE 52.2. Indeed, the ruling states that "USGBC would prefer to allow the use of effective dynamic filters for compliance." It can be proven that the proposed method filters particles to the level of MERV 13 and, therefore, meets the criteria of the standard. 2.) The International Mechanical Code allows the implementation of alternative materials and methods (Section 105.2) for equivalent compliance to those prescribed in its code. The IMC has this provision because it recognizes that technology changes more quickly than building codes. If a technology can be shown to be consistent with the intent of a standard and equivalent in performance, it is allowed. 3.) MERV 8 and 13 are cited as minimum levels of performance in EQ Credit 3. The purpose seems clearly to provide a minimum standard of air quality in buildings, not to promote the use of static filters. If a technology can be shown to produce equal or superior levels of air quality, there is no sound basis for rejection. 4.) In disallowing the request, it was cited that approval would require a substantial change to the credit as currently written and that the CIR process was not the appropriate forum for facilitating such a change. The project team is not asking for a change to the credit, only recognition that dynamic filtration exceeds the standard of compliance. 5.) The project team initially requested that this technology be granted a point for Innovation and Design. That request was denied on the basis that the system did not represent superior or exemplary performance (see CIR dated 7/10/03). If this innovation does not represent superior or exemplary performance to a standard LEED credit, then it is implied that it does, in fact, meet the standard credit. Since EQ Credits 3.1 and 3.2 are the only ones that address filtration of HVAC equipment, at a minimum, a superior filtration method to the ones cited in the reference standard should be granted equivalent status. Research studies have proven the effectiveness of UVGI. Penn State University's Department of Aerobiological Engineering performed one such research study. Many other health organizations including the Centers for Disease Control, and The Lancet medical journal support these findings. http://www.arche.psu.edu/iec/abe/wjkuvgi.html http://www.phppo.cdc.gov/cdcrecommends/showarticle.asp?a_artid=M0035909&TopNum=50&CallPg=Adv http://www.thelancet.com/ (search for ôUVGIö) http://www.katu.com/health/story.asp?ID=62778 Dynamic air cleaners and other active filtration technologies, are entirely consistent with the overall goals of USGBC and LEED to "produce a new generation of buildings that deliver high performance inside and out" and "that are environmentally responsible, profitable and healthy places to live and work." In fact, because dynamic air cleaners consume less energy and the glass-fiber media can be recycled, they would seem to be more in line with these goals than MERV 13 passive filters. Due to its superiority, this technology is being considered by the Department of Defense and Department of Homeland Security for use in critical facilities to combat bio-terrorism. In light all this evidence, we ask the committee to reconsider its previous decision and allow the use of the proposed filtration method to satisfy the criteria of LEED EQ Credits 3.1 and 3.2.
The project is appealing a 10/17/03 IEQ Credit 3.1 CIR and requests approval to use an alternative filtration method for installation after construction and prior to occupancy. The CIR was submitted under EQ Credit 3.2, but this ruling applies to both 3.1 and 3.2. The project has raised a number of strong arguments in making their case for the use of dynamic filters. However, there are some overriding concerns that lead the USGBC to remain cautious about this issue. To date, there are no studies that we are aware of that clearly equate the performance of electronic filters with those of passive filters. The requirements for these credits are based on the requirements of ASHRAE 52.2-1999, which define the Minimum Efficiency Reporting Value (MERV) of 13, as "the ability of the device to remove particles from the airstream and its resistance to air flow." The standard specifically states that the testing methods cannot be used to test electronic air filters. This issue is of concern because while the removal efficiency of a MERV 13 filter increases with use, research indicates that an electronic air cleaner's performance deteriorates rapidly, and it is therefore difficult to equate performance over time. In addition, the performance of the electronic filters depends greatly on frequent and thorough cleaning, which was not addressed in the CIR. As mentioned in the original ruling, the ASHRAE 52 sub-committee is in the process of reviewing testing methods for electronic filters, and is likely to issue an addendum to ASHRAE 52.2 in the near future. Once ASHRAE established an equivalency (hopefully before your project is submitted for LEED certification review), the USGBC will adjust its criteria accordingly. Until that time, MERV 13 filters will be required for both EQc3.1 and 3.2. -- *NOTE (Nov 1 2007): Per EQc3.1 errata posted in Fall 2007, there is no LEED or ASHRAE 52.2-1999 requirement for MERV 13 filtration during construction. LEED-NCv2.1 EQc3.1 requires MERV 8 filters on return air grills during construction, and for all filtration media to be replaced with MERV 13 immediately prior to occupancy/at the end of construction. LEED-NCv2.1 EQc3.2 (option one) requires MERV 13 filtration media at 100% outside air during flush out. Applicable Internationally.
Related Addenda (Corrections & Interpretations)