It is my understanding that the proposed version of LEED 2012 does not include an "equivalency" between ASHRAE 90.1-2010 and California's Title 24-2008 energy code.
Accordingly, I just posted the following comment.
Simply put, to discontinue the long precedent and tradition of allowing projects in California to use Title 24 - and instead, force these projects to demonstrate compliance with two different energy codes, will most likely:
a) increase costs for projects in California, which will...
b) discourage projects from using LEED 2012, which will...
c) result in fewer projects using LEED in the future...and thereby reduce the probability of the USGBC Vision from being achieved.
Accordingly, we implore you to reconsider this choice.
If not, we respectfully request that GBCI demonstrate complete transparency in this decision-making process, as follows.
1. Please provide access to all the specific backup documentation that GBCI relied on to substantiate the statement that "Title 24-2008 is generally not as stringent as ASHRAE 90.1-2010".
2. Please provide access to all the specific backup documentation that USGBC/GBCI relied on to substantiate the conclusion that the difference between 90.1-10 and T24-08 is *substantially greater* than the differences between *prior versions* of these respective energy codes, specifically 90.1-04 compared to T24-01, and 90.1-07 compared to T24-05 (which were all previously deemed substantially equivalent, of course).
3. Please provide the proposed timeline for evaluating the Title 24-2013 energy code for equivalency with ASHRAE 90.1-2010, and clarify what month and year this determination is expected to be complete.
Thank you in advance for your consideration of this feedback, and we look forward to your response.
If you agree that forcing California projects to be modeled using two different energy codes is redundant, does not follow previous LEED precedents, and most likely will result in fewer LEED projects, then I encourage you to submit a comment stating your concerns.
Thank you for reading,