CS 2009 IEQc5: Indoor Chemical and Pollutant Source Control

There is new legislation on the subject. Here is a link to the "LEED Addenda" website.
http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2200#BD+C
Because this is new legislation I can only give you my interpretation:
The intention of the correction is to clarify where the MERVMinimum efficiency reporting value. 13 filters should be located inside an AHU1.Air-handling units (AHUs) are mechanical indirect heating, ventilating, or air-conditioning systems in which the air is treated or handled by equipment located outside the rooms served, usually at a central location, and conveyed to and from the rooms by a fan and a system of distributing ducts. (NEEB, 1997 edition) 2.A type of heating and/or cooling distribution equipment that channels warm or cool air to different parts of a building. This process of channeling the conditioned air often involves drawing air over heating or cooling coils and forcing it from a central location through ducts or air-handling units. Air-handling units are hidden in the walls or ceilings, where they use steam or hot water to heat, or chilled water to cool the air inside the ductwork. that supplies OSA and recirculate air. The filter should not be at the OSA damper, but instead downstream of the mixing of the return air and the OSA to filter both the OSA and recirculated air.
However, an indoor fan coiling unit or heat pumpA type of heating and/or cooling equipment that draws heat into a building from outside and, during the cooling season, ejects heat from the building to the outside. Heat pumps are vapor-compression refrigeration systems whose indoor/outdoor coils are used reversibly as condensers or evaporators, depending on the need for heating or cooling. In the 2003 CBECS, specific information was collected on whether the heat pump system was a packaged unit, residential-type split system, or individual room heat pump, and whether the heat pump was air source, ground source, or water source. that is recirculating air to condition a space would not require MERV 13 if it is not pulling air directly from outside. Even if there is a DOAS providing OSA air into a mixing boxing in the back of the FCU/heat pump, it should still not require a MERV 13 filter (only MERV 8 for ASHRAE). The MERV 13 filter would be in the DOAS.
The legislation was changed in the first place because FCU's can't handle the pressure drop from a MERV 13 filter - I don't believe this legislation was intended to put that requirement back.

Nandor, I don't think this would be LEED-compliant. There is likely to be some air movement from the garage to the building unless there is negative pressure.

George- I am not an engineer, so I don't have the full technical answer for you, but the 5 Pa average takes into account the room door being open, while the calculation allows you to drop to a less stringent 1 Pa when the door is closed and contamination is less likely.

A high volume copy area is 40,000 copies or more per month.

According to CS Appendix 4, IEQc5 must be supported by tenant lease agreements.

I would meet the credit requirements for any space you are building out, make it physically possible for the tenant to meet all requirements, and require them to do so in the lease.

About this issue the GBCI technical customer service answered:

"...the requirements of a credit exclude the fit-out of tenant spaces. Tenant space activities such as use of copiers, fax machines, and printers are not considered within the scope of the LEED Core & Shell program."

So, Do we have to leave exhaust ducts for the tenats?

I don't really know what to make of GBCI's response. It doesn't address the key questions, which are a) tenant lease requirements, and b) including systems enabling tenants to meet credit requirements. I shared my thoughts on both topics earlier. I'll ask around for another opinion.

In the past, I have been successful providing any required exhaust in core spaces, making sure the mechanical systems are capable of allowing tenants to provide any required exhaust in their space and also writing the exhaust requirements into the tenant lease agreement. Of course, past acceptance doesn't gurantee ot for the future, but I think that you should be in good shape if you do these three things.

We have achieved this credit on a couple 2009 projects by just writing a good narrative and not providing additional supporting documentation. Of course, reviews vary a little from project to project, so that doesn't necessarily mean you won't need additional information. If I were you, I would submit with only a narrative and worry about additional documentation only if the credit is marked for clarification sduring the review.

It sounds like you are stretching it. I would take the regular doors with or without the sign directing me to use the revolving doors. Not wanting to do something that is a requirement is obviously not a convincing argument. If you could make an operational argument that, despite the number of doors required for egress by life safety codes, entering is always controlled by building management in a certain way (ie. "No Entry" on certain doors), then you might be onto something.

I see this often on buildings—signs directing you to use the revolving door, or just somehow people using the revolving door more often—but the secondary door still gets plenty of use. You'd have to truly limit use of this door to make this strategy work. Locking it might accomplish that, but that's counter to the need for egress and accessibility.

I agree with Tristan and Thorn- you';re going to have to provide entryway systems for these doors because they will get used on a regular basis.

Petr- you will need 10ft of entryway system in front of the elevators. Perhaps there is some sort of heavy grate system that be used where it crosses the traffic lanes.

Petr - if you can't manipulate the primary direction of travel to be out of the vehicle lane, perhaps try an alternate compliance path where 5' or 6' is outside, and an open grid mat on the floor of the elevator serves as the balance. Elevator floors always need frequent cleaning anyway. Has anyone else tried something like this?

The credit requirements have to do with providing suffcient ventilation of spaces where hazardous materials may be stored. If no such materials are stored in the project building then no, you don't have to meet that requirement.

Tristan, this CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide seems to say otherwise:

"2/7/2005 - Ruling
....Green housekeeping products still contain chemicals which need to be contained and dealt with per the credit requirements (albeit at lower levels). Therefore, even if the project only uses Green Seal compliant cleaning products, it would still need to meet the criteria of providing the ventilation requirements and deck-to-deck partitions. This is also noted in the CIR ruling dated 1/24/2005 which states that ôGreen housekeeping cleaners contain chemicals that need to be addressed.ö This credit does NOT differentiate between rooms that store Green-Seal-compliant cleaning products and those that store industry standard products.

The need for drains plumbed for appropriate disposal of liquid waste is a separate issue from the ventilation requirements. As noted in CIR ruling dated 2/18/2002, sinks that dispose of chemicals, such as detergents, which are approved by the local water treatment facility, can be part of a conventional sanitary drainage system. If greywater is being directed to re-use for irrigation or uses or to a natural wastewater treatment system, then separate plumbing would be required for disposal of conventional cleaning agents. Projects should check with their local treatment facilities to confirm what the jurisdiction requirements are for chemical disposal.

In response to the question raised in CIR ruling dated "1/18/2005, a project MAY be able to meet this requirement by only providing permanent walkoff mats and entryway systems if NO chemicals (of any type) are mixed and stored on-site. If any chemicals are mixed or stored on-site, then the criteria for containment, ventilation and plumbing will apply. " Or am I missing something? Thanks, John

John, great point. I'm going to ask around.

I have gotten a response on a past project that walls must be floor go deck and the ventilation requirements met even if green cleaning products are used, so I would encourage you to go ahead and follow the stated credit requirements.

Thanks, Allison--will do

I would say this is a gray area and it will be up to you to make your best argument to the reviewers that you shouldn't have to include entryway mats there.

It is outdoor space, and subject to dust, sand, pollen, animal incursion, and other things that create "pollutants" in outdoor spaces.

Think of it this way—would LEED allow you to skip the entryway for the front door just because your staff sweep the sidewalk once per day? I very much doubt it.

That said, I do think you have a point and could argue it, it's just by no means a sure thing.

Your graphic above says the walk-off mats are 6' long, but the text here, and the LEED text, says the walk-off mats must be 10' long. Just checking.

Yes, the graphic is intended to illustrate the type of documentation to provide. The actual requirement changed from 6 feet to 10 feet with the introduction of LEED 2009.

Can the 10 foot requirement be split up so that 3 feet are outside the buikding and 7 feet are inside, all 10 feet in the direction of travel? Even though not entirely within the building, keeping some of the mud, snow, and dirt outside the building altogether would seem to satisfy the credit's intent of minimizing "building occupant exposure to potentially hazardous particulates and chemical pollutants." Thoughts? Thanks in advance, John

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An old CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide seems to concur that an exterior matt could comply with EQc5 intent--agreed?

"10/7/2004 - Credit Interpretation Request
I am running into two interpretations for the location of the "permanent entryway system." One argues that the system should be outside the entry door so pollutants are scaped off and left outside the enclosed indoor space. The other argues that the system should be inside the entry because a mat outside could get wet and muddy thereby adding to the dirt and contaminants brought inside. Research on the issue has not revealed which is satisfying the intent of this point. i look forward to your interpretation.

11/1/2004 - Ruling
The intent of EQc5 is to prevent contaminants from entering the building which could have an effect on the indoor air quality. However, the location of the ôpermanent entryway systemö, for example grills and grates, is subjective, depending on the layout of the building. If there is a vestibule it may be appropriate to have a walk off area located within it. Also, exterior walk-off areas may be considered if the area is protected from weather. Alternatively, the walk-off area can be within the building. "

John, I think there is a consensus on LEEDuser (see the NC IEQc5 forum, if I remember right) that you can hat a mat that's at least partially outdoors if it's weather protected. Or it could be broken up in other ways, too, if there is 10 feet in the direction of travel.

Tristana, I agree with your concensus, thanks, but I just found the 2009 BD&c Ref Guide p. 513 (item 4, 4th para. under Implementation) says: 'Entryway systems must extend 10 feet from the building entrance into the building interior'. This sentence was not in V2.0, 2.1, or 2.2, and it seems to trump the CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide about an exterior system. Might this question need to be elevated to a CIR? Thanks again (and sorry I missed you at Greenbuild), John

Has anyone tried a partially indoor partially outdoor mat in 2009? This new phrasing does seem to trump previous CIRs and rulings, so I would be very cautious about trying the half and half method in 2009 without a CIR.

This isn't the first case where the Reference Guide and the Credit Form in LEED online contradict one another.

My first line of defense would be to send a technical inquiry specific to the credit to GBCI and have them acknowledge the difference and to confirm if the legal language is required for credit compliance (more so than the recommendation to include in the Tenant Guidelines).

Most tenants won't have copiers and printers that are high volume enough to require placement in a separate room with negative pressure and exhaust, though some might.

We recently completed a LEED CS building that included reference in the lease to a "LEED Tenant Directive" for all tenants. In this we addressed design issues for all tenants that affected the base building - i.e. all tenants were required to reduce LPDLighting power density (LPD) is the amount of electric lighting, usually measured in watts per square foot, being used to illuminate a given space. by 15% at a min, all tenants were required to recycle construction waste, and meet all EQc4 requirements, among a few others. The directive laid out the specific design requirements as well as the process by which the owner/property manager would check the inclusion during design reviews. The LEED directive and the Tenant Guidelines were linked documents.

So the owner was able to require certain LEED specific design items by reference to the LEED directive in the lease, without the wording actually showing up in the lease itself. The wording for an item such as this could be to the effect of "in the event the tenant requires a separated high-volume copy area X Y Z ventilation requirements must be met in accordance with LEED CS 2009 EQc5 requirements."

Good luck!

finally a response to my technical enquiry: legal language definitely required! Thanks for your additional help and advice, Susie!

Response from USGBC Technical Customer Service:
" If future tenant spaces are anticipated to have “high-volume copy, print, and fax equipment” located within the building, then your Core and Shell project must include a legally binding document that states these spaces shall comply with the requirements of IEQc5 when completed, as stated in the 2009 LEED IEQc5 Form, if you wish to achieve a point for this credit. Because this is a “Case C” credit, as explained in CS Appendix 4 on page 620 of the LEED Reference Guide for Green Building Design and Construction, 2009 Edition, it is required that the project team provide tenant lease or sales agreements to support IEQc5 compliance data. Please note that the requirements of such agreements would only apply if the tenant’s project fit-out actually involved high-volume copy, print, &/or fax equipment. "

George, I would be curious if anyone else has had a different experience, but I very much doubt that you could earn this credit with a system less than 10 feet.

The only possibility I can think of is that if you are using LEED-CS v2.0 (an earlier version), the requirement is only for 6 feet.

From your description it would seem one recourse might be to include the entryway mat flooring into the elevator, assuming the combined depth would be 10' (and would USGBC count to the middle or to the back of the elevator - anybody's guess). Also - the elevators might not be the only way into the building - the path to stairs or a first floor room would have to be covered. Another option would be to get the city to accept a small portion of a recessed mat on the city sidewalk, so the total was 10'.