Our project team wants to verify an acceptable compliance path for achieving the EQp1 Minimum IAQ Performance in a mid-rise apartment project with recirculating kitchen exhaust and operable windows. We have reviewed the CIR ruling dated 9/24/2007 and we are requesting clarification on part of this ruling. The ruling states which calculations must be presented to prove that a space is naturally ventilated: "Calculations to demonstrate compliance with ASHRAE Standard 62.1-2004 for naturally ventilated spaces will include showing adequate operable window opening area, and/or permanently open area to another space that is naturally ventilated (the total areas of both spaces have to be included in the 4% operable window opening area calculations.)" Our question pertains to the second part of that statement. We are trying to understand how to interpret the code in the following instance. If a kitchen without an operable window and a recirculating fan is 1. immediately adjacent to a living room with an operable window AND 2. that operable window is more than 25\' away from where the kitchen begins AND 3. the space between the kitchen and the living is completely open- that is, the floor plan is "open" and there are no obstructions between the "kitchen" and the "living room"- May the kitchen in this case be considered naturally ventilated?