22-0322 Natural Materials Affordable Housing IAQ Exemption

QUESTION:

In accordance with Health and Happiness requirement I10-1, the project team has decided to pursue an exception for the Indoor Air Quality Test requirements for LBC Certification. As an affordable housing project located in a rural community, several challenges arose when searching for a qualified Indoor Air Quality professional in even semi-close proximity to the project location. The project team sought out bids up to 300 miles away, which accrued high overhead costs in all bids, specifically when the addition of mobility and overnight fees are were included in the cost of testing. Ultimately, the funding source of the project being largely through the USDA rural development loans and out of pocket costs paid for by an affordable housing non-profit such as Community Rebuilds, the project team determined that the homeowner’s budgets could not accommodate the prohibitive costs of such an endeavor.

In order to counter this setback, the project team assessed the materials and construction methods used towards the completion of these homes. With the prevalence of natural materials involved in nearly all the major structural components of the home, as well as substitutes for many of the commonly used materials that typically contribute to poor Indoor Air Quality, it is the belief of the project team that most of the toxins/pollutants being tested for the indoor air quality would not be found upon the type of IAQ testing we were seeking for LBC compliance. One such example of material substitution for a typically toxic or synthetic material are the adobe earthen floors, sealed with organic linseed oil. Additionally, the walls are all plastered with earthen clay plasters made of kaolin clay and two different types of sand, colored with natural pigments and do not contain any VOCs, which are typically contained found in most widely available paints. The homes are also outfitted with energy efficient HVAC systems, containing filters that circulate air to remove fine particulates and allergens from the outdoors. Each home contains an installed humidistat, which monitors and controls the home’s moisture level. Each homeowner was also passed along a custom digital guide with preventative tips to clean and care for their home while avoiding harmful IAQ substances. All of the homeowners were readily receptive of these tips and eco-conscious, and do not plan to use harsh cleaning chemicals or bring in new furniture or appliances that cause additional off-gassing or harmful side-effects. Below is a list of all of the materials that were wet applied to the interior of the homes. If you’d like to see all of the materials we tracked that went into the homes, you can reference our materials tracking sheet from the materials requirements.

ANSWER:

The project must conduct indoor air quality monitoring, but it may meet requirements using a new pathway within the Continuous Monitoring approach available to single family residential projects of 4 units or fewer. The new Single Family Home pathway is provided below within the context of the broader Continuous Monitoring clarification. Note that the existing clarification has been edited for clarity, but the requirements have not changed.

Continuous Monitoring

Project teams may meet indoor air quality sampling requirements by showing compliance with an ILFI-approved continuously monitored indoor air quality standard in lieu of performing a comprehensive IAQ test one to six months after occupancy.

Projects pursuing the continuous IAQ monitoring pathway must additionally perform IAQ testing, at one to six months after full building occupancy, for any pollutants in Table 10-1 that are not monitored by the continuous monitoring devices accredited under the ILFI-approved standard. For example, some systems do not monitor PM10, Formaldehyde, Carbon Monoxide, Carbon Dioxide, Nitrogen Dioxide, Ozone, and Radon, so project teams would need to perform the one time IAQ test for these substances and show compliance with the thresholds in Table 10-1. If projects do not pass any of the spot tests, remediation measures must be implemented and a re-test for that pollutant subsequently performed to confirm that thresholds are met.

Continuous IAQ monitors must at a minimum monitor for:

  1. PM2.5
  2. Total VOCs
  3. CO
  4. CO monitors must be installed  and comply with guidance provided in the Healthy Indoor Environment Plan clarification under Imperative I09 Healthy Interior Environment 
  5. CO2
  6. CO2 monitors must be installed and calibrated to 1000 ppm; or in Transects L3-L6, +500 ppm from outdoor levels.
  7. Temperature
  8. Humidity
    1. Both temperature and humidity must be monitored; no maximum levels are specified.

Approved Continuous IAQ Monitoring Standards

RESET Air is an ILFI-approved continuous IAQ monitoring standard. By the end of the LBC project’s twelve-month performance period, the project must be RESET certified and additionally have passing test results for any required IAQ spot tests for pollutants not measured by the continuous monitors, as described above.

Project teams may request approval for alternate continuous IAQ monitoring standards through the Dialogue, noting that any proposed alternate standard should include specific requirements for equipment certification, system installation, and data collection.

Single Family Homes 

Single family home projects consisting of 4 units or fewer wishing to pursue the continuous IAQ monitoring pathway must meet all requirements identified above under the Continuous Monitoring clarification, with the following differences:

  1. Only monitors accredited by ILFI-approved continuous monitoring standards may be used. They do not need to be permanently installed, but must be installed and provide monitoring data for a minimum of 30 days without interruption.
  2. Monitoring and any spot tests must occur in each residential unit at the frequency of 1 dataset per 2,000 sf of area
  3. Monitors must be placed in the location that represents the potential worst case scenario for indoor air quality
  4. Certification under ILFI-approved standards is encouraged, but not required, however data from the continuous monitor and any required spot tests must show compliance with the maximum concentrations for all  of the pollutants identified in Table 10-1. 
  5. Notwithstanding the pollutants listed in Table 10-1, project teams may omit testing or monitoring of:
    1. Carbon monoxide and nitrogen dioxide if they can demonstrate that there is no attached enclosed garage, or combustion-based appliances or equipment within the building footprint as might be permitted in accordance with limitations specified in I07 Energy + Carbon Reduction.
    2. Ozone, if they can demonstrate that there is no potential source in the home, including ozone generators sold as air purifiers.
  6. Radon sampling results from pre-construction monitoring are acceptable, except that if results show concentrations in excess of the threshold cited in Table 10-1, measures must be installed to ensure radon does not enter the home. An additional short- or long-term test must be conducted 1 to 6 months after project completion with results showing compliance with the thresholds in Table 10-1. If thresholds are exceeded in the post-construction test, remediation measures must be implemented and a re-test subsequently performed that confirms that thresholds are met.

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