21-1216 Older Building Documentation for CORE Projects without HVAC Scope
We would like to request an exception for projects without HVAC scope regarding the requirements for I09-1, HVAC Documentation. CORE projects are currently required to provide the following:- A statement from the project architect or mechanical engineer confirming project-wide compliance with current ASHRAE 62 or international equivalent, as well as relevant calculations, narratives, diagrams and/or drawings applicable to ASHRAE 62 compliance.- Documentation showing the direct exhaust systems requirement has been met for required spaces, as well as any copies of relevant HVAC drawings.
The scope of our tenant improvement project does not include HVAC improvements. Although we did adjust the location of several HVAC supply and return heads, we did not make changes to the system, branches, or filtration. Our office is located on the fourth floor of the Polson building, which is a 5 story building built in 1910. The building is supplied by a central unit that was last upgraded around 1996-1998. The system does not likely comply with ASHRAE 62, nor can we make modifications as tenants that would make the system compliant. Since our project did not modify this system and we are unable to modify the central unit or intake, there are no mechanical engineering calculations, narratives, diagrams, nor drawings produced as products of this renovation.
ASHRAE 62 maintains ventilation and occupant comfort standards, and to that effect several years prior to this remodel, we rebalanced the office and in this past year we introduced four independent air filtration units around to office as part of our COVID response. These unrelated efforts, although they improve the comfort of occupants, will not bring us closer to meeting ASHRAE 62 in a meaningful way.
To require this documentation and work for our project would necessitate costly additional scope beyond our reach to satisfy compliance.
A standard clarification which explicitly articulates an exception for CORE projects without HVAC scope is requested.ANSWER
Interior projects in existing buildings are not exempt from the requirement to provide fresh air to the space per applicable ASHRAE 62 requirements. Absent documentation through, for example, building drawings, calculations, including data from previous upgrades and balancing of the ventilation system, or empirical data such as from flow hood testing, it is difficult to draw conclusions about the ventilation status of the space or the extent of occupants' access to healthy indoor air.
The Dialogue post does not demonstrate due diligence in either establishing the current, or even the most recent available ventilation conditions, identifying what would need to be done to bring the space into compliance if found deficient, or advocating to the property owner to make any needed improvements. An exception to the I09-1 HVAC documentation requirements is not granted.