We have a mountain village project that consists of multiple stories of residential units above a first floor which will house retail uses. We are reviewing the project for compliance with IEQ credit 6.1-controllability of systems for perimeter spaces. Our exterior wall in the retail area typically consists of fixed storefront glazing, with at least one storefront glazed door per tenant space. As you know, the point requires that we provide at least one operable window and one lighting control zone per 200 sf of all regularly occupied areas within 15 feet of the perimeter wall. Is it possible to count the exterior doors on this retail level towards the requirement for operable windows under this point, or must we exclude the doors from the equation, and provide separate operable windows? In many cases, the doors will be propped open for fresh air on nice days, as desired by shopkeepers, so I would expect that the door would serve the same purpose under the spirit of the point.
The exterior doors in the retail level do not offer the same level of ventilation control as operable windows. Even though the shopkeepers have the option to keep the doors open on days when the weather is nice, the doors may be kept closed in light of security issues. The CIR ruling dated 8/6/2002 discusses this issue for a similar application.