Green Building

 
REGULATORY INTERPRETATIONS

REGULATORY INTERPRETATIONS

This section outlines the response and interpretation of EHS sustainability department for the queries raised by several stakeholders in the process of administering the green building regulations for their projects at various stages. Although these are general issues, it should be duly recognized that the response has been provided specific to the circumstances surrounding those specific projects. While this section provides a broad picture of the issues and the interpretations, it is always prudent to check with EHS for any specific challenges. Besides this we encourage and advise stakeholders to keep themselves abreast of the latest by looking out for circulars and announcements that are being released by the department on regular basis

 

March 2016

Query

I have noticed that the Accreditation course title is "Green Building Regulations for Warehouses and Industrial Developments".  So, I would like to confirm if I can submit for green building approval for small projects like group of villas after getting accredited or I will need to hire Third Party Company still.

EHS Response / Interpretation

Further to your mail, please be advised that the Accreditation program that we currently offer pertain to the Green Building Regulations for Warehouses and Industrial developments. Hence this is mandatory for consultants and contractors working on warehouse projects.

However, as of now, there is no separate accreditation program for villa developments although the villa regulations are pretty much similar to warehouses. Hence if you get accredited for warehouses you would be in a better position to work on the villas as the program guides you through the credits and compliance requirements. That is the reason we encourage villa consultants also to undertake the accreditation program

To conclude as far as villas are concerned

  1. Warehouse Accreditation is encouraged although not Mandatory.
  2. Hiring a Third party green building consultant is OPTIONAL. This has been the position right from the inception of the villa regulation

Query

There was a comment from EHS on the thermal imaging report that we submitted for one of our projects. The comments suggested that it has not essentially followed the best practices. The company that carried out the test expressed limitations of the regulations. How should we prevent this in future?

EHS Response / Interpretation

Further to your mail we are of the opinion that the thermal survey which is carried out to meet the requirements of our regulation (Ascertaining Envelope tightness through thermal imaging), if attempted on a yet to be completed building does not serve the purpose. We have had several instances where a thermal survey is delayed either for permanent power or project completion which understandably take into consideration the best practices or industry standards irrespective of whether they are explicitly referred to in the regulation. You should note that thermal imaging is just one part of the entire green building regulation and hence the prescriptive regulation is not an exhaustive guide. We have attempted to provide technical information on the subject in our guideline section. It is anticipated that the guidelines complimented by the experience of certified thermographers would be sufficient enough to support the green building movement. Hence we consider it a genuine responsibility of the qualified thermographer to guide the consultant and the client after ascertaining the ground reality rather than completing it abruptly and citing regulatory limitations. They are there for a purpose and the purpose is to put their expertise for meeting the objective. Please be reminded once again that this initiative IS TO SUPPORT THE PROJECT AND HELP SAVE ENERGY BY PREVENTING LEAKAGE which is achieved only through best practices that include proper planning, involvement and genuine stakeholder communication.

This situation also springs out of limited awareness wherein the stakeholders consider thermal imaging as a rudimentary exercise to satisfy the authorities. It is advisable to consult EHS department under such circumstances

Query

We are working on a villa development wherein the developer intends to sell these villas to prospective buyers. On the specific credit requiring the use of renewable source of energy for domestic heating requirement (Solar Hot Water System installation), the client wishes to provide an option for the same to be installed on the villa roof and will ensure that this requirement will be conveyed to the prospective buyers within the sale agreement. Is it acceptable?

EHS Response / Interpretation

Your communication indicates that the developer intends to install standard electric heaters for the proposed villas. It also indicates that the developer would like to make a provision for solar thermal systems and that too at the option of the end user if required. Please note that it is quite unlikely that the end user would propose / attempt to comply with a regulation that has been ignored by the project in the first place. Solar thermal systems play an important role in reducing the reliance on grid for domestic heating. Being a residential development this is expected to generate benefits. Do please clarify as to why you are not considering these in your project and attempting to drive it through the end user.

Query

We have received your response on the project submission for a villa development. There was a specific reference to the U value that we had submitted. We would like to clarify that we had referred the guidelines that you have uploaded in the portal

EHS Response / Interpretation

Please be advised that the guideline is provided to familiarize the stakeholder with several envelope possibilities based on the information received from the stakeholders. This guideline should however not to be construed as a scope that is specifically required by EHS towards compliance. It is strongly recommended that the stakeholders, while using the guideline for an objective understanding, take to the recourse of strong fundamental design integration and analysis to ascertain the true thermal characteristics and performance of the sections being used by them for their projects. In your specific case, it was noted that the wall u-value is higher than the regulation requirement. Also glass VLT was NOT mentioned.

Query

We are doing group of villas and townhouses for a developer. We have already obtained the EHS-BP-NOC approval for two typical villas and one townhouse till date. We would be soon applying for remaining three typical villas and one townhouse EHS-BP-NOCs. We understand that the repeat villas could be submitted as a group submission with a reference to the respective typical villa EHS approval.  We request you to please confirm this and advise us on the submission process for repeat villas so that we could speed up the approval process for the same.

EHS Response / Interpretation

Further to your query, please be advised as follows

  • It is the developer's choice on the number of project submissions i.e. single submission with multiple adjacent plots or multiple submissions for several plots. You may discuss this with our permits / drawing review department to discuss the options.
  • Once decided, please ensure that the submissions for green buildings align to the submission for NOC-Drawing review. In other words, both drawing review submission as well as green building submission should refer to the same group of villas. These would be jointly reviewed and responded. 
  • As far as green building department is concerned, group submission for a typical type villa is acceptable as long as the submission for the drawing review includes the same set of villas.
  • We note from your mail that you had sought the services of a green building consultant for making your submissions. It is important that you follow the same design principles for all your villas and townhouses. Your submission should adequately reflect this.


February 2016

Query

We have received a comment from the Green Building department informing us that we have not made any GB submission and should be a part of the NOC-BP submission. In this regard would like to set up a meeting with you. Please advise

EHS Response / Interpretation

Further to your mail please be advised that green building submissions are mandatory and has been in enforcement since 2008. For your project, we note that you have not made any submission. Accordingly the department has reverted with its comments and has further provided adequate guidance be referring to the actual regulation, The Procedures and the Forms to be used for the submission. Please follow the regulation and procedure to understand the submission requirements.  Should you still need some guidance after that, you may contact us.

All consultants can are expected to know the process and hence should assist the client accordingly.

Query

Our certificate for EHS Trakhees Green Building Regulations expired on 23rd October 2014.

Can you please advise how much we need to pay to renew our certificate for offering Green Building services?

EHS Response / Interpretation

Given that your prequalification expired in 2014, it would be a new application and accordingly would be governed by the following documents

EHS-GBP-01    Procedure for Registration-Renewal of Green Building Consultants &                             Specialists

EHS-GBP-02    Procedure for Registration-Renewal of GB Commissioning & Allied                                 Specialists

GBF-01a          Pre-Qualification Form (New-Renewal) - Green Building Consultants

GBF-02a          Pre-Qualification Form (New-Renewal) - Commissioning Specialist

Guideline          GB-001 Guidelines for General Deliverables of Green Building Consultants

Guideline          GB-002 Guidelines for General Deliverables of Commissioning Authority

Query

The project is currently under construction and submittal reviews and approval is on-going. The supplier has a specific query on 400W Metal Halide High Bay Light as substantiated in the attached letter. Keeping in mind that fixture with magnetic ballast is prohibited, we kindly request for your advice on the way forward based on the proponent's appeal as a special case.

EHS Response / Interpretation

Further to your query, please be advised that the Regulation was established after checking the availability in the market. Hence we are unable to accept your point on the non-availability. Magnetic ballasts are not acceptable and hence we ask you to use electronic ballasts that save energy all through the operations of the lamps.

Query

There is an existing refinery in Jebel Ali which has a proposed expansion project (addition to existing building) planned. The detail design is not commenced yet. The expansion project includes two unmanned substations including Rack room (rack rooms are not separated from substation building and one satellite operator building

EHS Response / Interpretation

Further to your enquiry, given the industrial setting of the project, we ask you to follow the Warehouse regulation i.e. Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments and comply with the relevant and applicable credits.

Query

We are working on a project that is likely to undergo a design change. The building footprint and the total built up area will likely be lower and also there will be changes in the interior layout. Please advise;

  1. If the design team and the owner provides a declaration that all the design specifications will remain same in the re-design, will this be sufficient to maintain the validity of the already awarded EHS BP-NOC?
  2. If the EHS BP-NOC cannot be valid under the circumstances, then does this require a full re-submission of the GBPP Report for EHS BP-NOC?

EHS Response / Interpretation

Further to your mail advising us of the likely changes in design we would like to affirm that as far as the sustainability department is concerned, a narrative of the changes along with its impact on the earlier green building report / project plan on the basis of which an earlier approval was granted to you is required at a minimum.

  1. In case there is absolutely no impact on the sustainability compliance including the achievable credits, you may mention it in the narrative and this would be taken into records
  2. In case there are few changes and hence an impact on few credits, those should be explained in the narrative and a revised credit summary should be submitted as an update to the earlier document
  3. If the changes are significant, a new full-fledged submission is inevitable

As regards the validity of the earlier NOC, please ask your AEC (consultant of record) to communicate with our permits department.

Query

We received an RFP from an oil contracting company requiring TRAKHEES Green Building certification – they are expanding by adding 3 structures:

1.     Substation A: 2,000m2 – unoccupied structure

2.     Substation B: 1,500m2 – unoccupied structure

3.     Operator Building: 67m2 only – occupied structure

The nature of this project is not really standard, so I am writing this email to enquire about the best way to certify these structures: shall we go for GB Regulation 6.0 (Industrial facilities), or should we go for Regulation 4.0 (in-house certification)? Note that in any case, many credits will not be applicable as project is mostly unoccupied.

EHS Response / Interpretation

You shall follow the GB – 6.0 Regulations for warehouse and industrial developments and you can submit the compliance for ONLY the applicable credits.

Query

Further to our discussion on the subjected project, we hereby seek for your guidance and confirmation on the applicable EHS GB guideline for the extension components of an existing and operational project. The area details for warehouse extension project are as follows:

Warehouse Extension – 451 SQ.M

Storage -195 SQ.M

Mess hall, Prayer room and ablution room – 91 SQ.M

Electrical Room – 22 SQ.M

Substation -54.90 SQ.M

Total area of the extension project is around 820 SQ.M.

Conditioned area of the project is: - Mess hall, Prayer room, ablution room Guard room and electrical room. Total Conditioned area is 126 SQ.M

EHS Response / Interpretation

You shall follow the GB – 6.0 Regulations for warehouse and industrial developments and you can submit the compliance for ONLY the applicable credits.

Query

We have an office building (proposed) (new lease drawing attached) that will be part of an existing warehouse and office building under the same owner. The client rightfully wishes to follow EHS GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments for the proposed extension. Kindly confirm if the proposed way forward is acceptable to proceed.

EHS Response / Interpretation

You shall follow the GB – 6.0 Regulations for warehouse and industrial developments and you can submit the compliance for ONLY the applicable credits

Query

We want to double check with you if we can install "Induction Lighting" in warehouse project, as long as they fulfil the lighting power density recommended by EHS TRAKHEES Regulations. The lighting designer is claiming that Induction Lighting is a bad choice as it has a low Colour Rendering Index CRI, and it produces electromagnetic pollution – please see below highlighted email. When it comes to EHS TRAKHEES, do you have any objection towards Induction Lighting?

EHS Response / Interpretation

From the sustainability (Green Building) department point of view, we can confirm that Induction lighting is acceptable for the warehouse projects as long as they comply with the regulations. We do not have any objections.

However if your client's project is of such a nature that it is not acceptable to have an induction lighting, that is something you may have to deliberate with your team. Hence we are unable to comment on your consultant's comments.

Query

With specific emphasis towards the subjected project, we hereby seek for your consent on the current Waste Management Aspect and the logs wherein the respective construction team are not able to attain the required waste manifest that quantifies segregated quantities

The current practice of waste collection only facilitates steel and wood waste to be hauled separately but all other waste although segregated by the contractor for the sake of EHS Green Building Regulation Compliance is collected and hauled together by the waste contractors ,thus making this a futile and redundant exercise.

EHS Response / Interpretation

We understand from the waste management company that there is a specific contract in place between them and the contractor to collect the general waste and the recyclable waste separately.  They have further confirmed that all collected recyclable waste is indeed recycled and that the waste collection reports have been sent to the contractor.  We ask you to exactly specify the nature of contract that the project has entered with the waste management firm. We would further like to add the following

1.      If it is for comingled collection you may provide us the reports / log of the TOTAL collected quantity (comingled recyclable materials ) that were diverted from the landfill

2.      If they are segregated collection, provide us the category wise log / estimate of the quantities diverted from the landfill

We do recognize the limitations with regards to Concrete; however going by the discussions that we had with the waste management firm, the logs / reports of the recyclable materials collected by them should be available with the contractor which you can produce to EHS.

Query

We would like to obtain additional guidance on how to comply with the Regulations in following aspects

a) Envelope and Energy

b) Envelope Tightness

EHS Response / Interpretation

Please find our response as under:

Envelope & Energy

Please note that we have a Guideline in our portal called Guideline No GB-008 – Envelope Compliance Strategies. This provides information on several sections that would help in achieving your U value. Please review it and if you still need assistance contact the department

Envelope tightness (thermal imaging technique).

There are 2 ways of doing it.

  1. Prescriptive approach:  Thermal Imaging.  This is Economical, simple and convenient
  2. Performance based approach:   Blower door test which is more comprehensive but more expensive

That is the reason the 1st one is mandatory whereas the 2nd one is voluntary. Either way this is an important requirement to prevent energy loss and save money for the client in the operational phases of the building

Query

On the subject of "Limiting/reversing thermal bridges", if we propose external insulation on elements like beams, columns, intersections of columns and slabs and concrete block with insulation insert, will continuity of the thermal insulation approved?

EHS Response / Interpretation

Your strategy is correct and helps in breaking the bridges

Query

We are interested in becoming authorized by EHS for Green Building Commissioning. Please advise the procedure, Thanks,

EHS Response / Interpretation

We thank you for your mail and would further direct your attention to specific sections of the portal that explains the prequalification areas and the associated procedures. They are

  1. Green Building Department HOMEPAGE
  2. Commissioning specialist -Prequalification Procedures
  3. Guidelines
  4. Forms

Should you need any further information do not hesitate to review our Portal or contact our department


January 2016

Query

We are consulting for 2 warehouses in Techno Park Dubai under EHS TRAKHEES GB Regulation 6.0. For credit B13 (Energy Metering), the MEP Engineer confirmed that it will be very difficult to provide separate electricity meters for AC, Lighting, and Power. Please see attached the 2 letters for both projects sent by the Main Consultant justifying the request. Can you please confirm if we can omit this specific credit from our assessment?

EHS Response / Interpretation

Further to your query, please be advised that sub-metering / check metering is a mandatory credit in order to develop the infrastructure for measuring and monitoring the energy consumptions of building energy systems. This strategy has wider significance from the context of energy consumption and benchmarking as well. As you have rightly mentioned, the regulation calls for check meters for AC, lighting and small power. These meters at the basic level can be manual ones that are fixed on to the panel facia or mounted separately. This has been followed in all the projects and hence we ask you to comply with it.

If the loads of the lighting and small power are quite small in comparison to the HVAC loads, we may permit 2 check meters one for the HVAC and the other for small power / lighting instead of 1 each for HVAC, Lighting and small power

Query

We are going to submit town-houses and it is the first time to submit for EHS, we need just to confirm that the standard EHS from as per attachment and what is the procedure of submission.

Another technical issue referring to maximum U-VALVES which mentioned in attachment is less than DM requirements for external wall, floor slab and roof slab , shall we comply with it or we can follow DM u-value limitations . your response and support is highly appreciated.

EHS Response / Interpretation

1.      Please note that you have to follow our regulation (including U values)   and associated procedure for submissions. These documents are available in the portal and explained below. 

2.      Please follow Regulation GB- 8.0 Green Building Regulations-Villas and Residential Developments upto 3 habitable floors

3.   Please follow the procedure EHS-GBP-09 Procedure for NOC-BP Green Building Submission (Villas) in order to understand the submission requirements for projects following this regulation.

4.     Please submit duly filled GBF-09 Submission Booklet [NOC-BP - VILLAS] The submission should be complete with all the supporting documents as prescribed in the Regulation GB-8.0 with proper segregation and arrangement of folders for various items in the respective category of the regulation.

5.      Please refer to the portal www.ehss.ae for downloading the regulations, forms and the procedure.

PS

Seeking the services of EHS approved green building consultant is VOLUNTARY as this regulation has been structured in a prescriptive manner that can be handled by a competent architect of record. However if you are of the opinion that you do not have enough knowledge on the regulation or EHS procedure (or you do not have time ), you may engage a green building consultant to understand and apply the regulations to your project.

Query

We kindly request you to provide a clarification for a particular enquiry we received. The project is a multi-storied Car parking facility with an Office space of only 104m2 on the Ground Floor. We have attached the perspective of the project to give you a better understanding. Kindly let us  know if we have to obtain Green Building Approvals for this facility. Your prompt response would be highly appreciated.

EHS Response / Interpretation

Further to the above, you may follow the GB regulations for the office area. For the car park although we do not have a specific regulation, you may address basic aspects such as lighting, cool roof, etc. as an initiative.

Query

With respect to the above subject on the issue of the water heaters, please be informed that as per the MEP design 78 Nos.  Solar Water heaters were considered for warehouse office (Toilets & pantry). 

Due to the smaller amount of Hot water consumption, at present the electrical water heaters are not necessary for the warehouses. During the construction  MEP provisions for Hot water if required in future which shall be fixed under our  guide lines for solar water heaters under the tenants expenses. Kindly confirm the above same to proceed further and complete the required. Thank you for your cooperation and looking forward to hear from you soon.

EHS Response / Interpretation

Further to the above subject and telephone discussions, we would like to confirm as under:

1.      If you do not foresee hot water requirement for office toilets and pantry, then solar thermal systems are not required. The solar thermal system that is part of our green building regulation is meant to be used to replace electrical systems. This is to reduce reliance on grid power and encourage adoption of renewable energy.

2.      However, if there is a proposal to make future provision for hot water, we strongly encourage you to explore the solar thermal systems as a priority. This becomes essential unless your study proves that it is economically and commercially non feasible.

3.      If you have already carried out such  a study, you may send us the report for our review and records

Query

For one of our projects we're working on, we already submitted for Building Permit and received the comments from EHS. Does the main consultant need to get this accreditation complete before we resubmit the documents for Building Permit? Or is it fine if the consultant registers for the accreditation and completes the procedure later?

EHS Response / Interpretation

The contractor can register at the accreditation department and complete later


December 2015

Query

Due to certain design requirements/restrictions, the project wishes to provide roof tiles that invariably will serve as pool deck as well. As per the attached mail and the documentation, we seek for your pre-approval on the roof/pool deck floor tiles with SRI of 60 as a special case applicable only to this specific project.

EHS Response / Interpretation

Further to your mail on the subject, we have reviewed its contents in the light of your requirements and would like to put forward our views as under.

  1. As you would appreciate, the purpose behind the regulation is to achieve a high Solar Reflectance Index (SRI) roof which helps in maintaining the roof temperature at a lower level than traditional roofs during sunny periods. This assists a long way in reducing the air-conditioning loads and hence the energy bills
  2. We do not believe that the High SRI roof tiles are always slippery by default. Our experience suggests that it is possible to achieve high SRI while still retaining the functional requirements i.e. Anti-skid / Non slippery /non glossy finish
  3. We ask you to explore the possibilities with your clients / engineering consultant so that you are able to comply without compromising the functional needs.

Query

We would like to know how to obtain LEED certified site for our current operation

What are the procedures? We need your guidance, attached is our affection plan.

EHS Response / Interpretation

Further to your query on your proposed project, please note that it would be governed by EHS in house green building regulation "Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments".  However if you would like to pursue LEED certification , you may pursue directly with GBCI USA.  You may initiate discussions with any of EHS pre-qualified Green building consultants http://www.ehss.ae/forms/ehsapprovedgreenbuildingconsultants04-11-2015.pdf . You would be able to access the entire set of documents at www.ehss.ae under the green building department section


November 2015

Query

We have two queries related to a  project;

The project is considering 5% of parking spaces to be reserved for LEFEV and 5% for Carpool Vehicles. Since the credit requires these spaces to be "preferred", it is suggested that reserving the spaces for such vehicles be meet the requirement of "preferred". Technically spaces closest to the lift lobby entrances are considered as "preferred", however,  due to the large number of such spaces for mall type projects, it is practical to keep the spaces in one zone  with proper signage. A sample parking layout with proposed LEFEV and Carpool locations is attached for your comments and acceptance.

The owner wants more parking which will exceed the authority requirement as they expect large number of visitors in this mall. Hence a "soft approach" is requested to SSc4.4-Parking Capacity. The second part of the credit requirement requires 5% of parking to be marked for "Carpool/Vanpool" vehicles in preferred locations. Since the project is not meeting SSc4.4 due to parking exceeding the authority required, can carpool spaces also be exempted since a large number - 418 Nos (5%) would be required to be reserved for such vehicles!

EHS Response / Interpretation

Further to your query, please advise as to why the LEFEV spaces are not being staggered across various lift lobbies. Frim the end user point of view and the definition of "Preferred" it is only anticipated that the end users visiting  the mall at various  entrances take advantage of those spaces rather than parking at one common location. This also dilutes the purpose of the credit

Please clarify on the Trakhees allowable parking spaces for this type of development and the spaces that you plan to provide for this development. We are of the opinion that it should in-principle be honoured. The same approach is applicable to the car pools.

Also we encourage you to explore bespoke or alternate compliance paths which collectively meet the intent of the credit

Query

A client of our company is planning to build a new residential building of around 22.000 m2 in Dubai. First of all I would like to ask if it is mandatory to be certified according to LEED by USGBC or it can just take the In-house Certification. Additionally, I would like to ask you if it is mandatory for the Green Building Consultant to be approved by the EHS in Dubai, and if yes could you please tell which is the procedure (e.g. we have to attend to courses or we can based on our experience up to now, etc.) and how long it takes the whole approval process.

EHS Response / Interpretation

Further to your query, please note as under

1.      Compliance to EHS  Green Building regulations is mandatory

2.      Certification. Yo0u can pursue GBCI or In-house certification. It is the client's choice

3.      It is mandatory for you to appoint a green building specialist from our prequalified list.

4.      Important links are reproduced for your ready reference

  1. EHS-GBP-03 Procedure for Ascertaining EHS Green Building Regulations Applicability to a Project
  2. EHS-GBP-05 Procedure for NOC-BP Green Building Submission (LEED based Regulations)
  3. EHS-GBP-13 Client Procedure for Green Building Certifications - New Building
  4. EHS Approved Green Building Commissioning / Allied Specialists
  5. EHS Approved Green Building Consultants
  6. EHS-GBP-01,Procedure for Registration-Renewal of Green Building Consultants & Specialists
  7. EHS-GBP-02, Procedure for Registration-Renewal of GB Commissioning & Allied Specialists
  8. Guideline No. GB-001 Guidelines for General Deliverables of Green Building Consultants
  9. Guideline No. GB-002 Guidelines for General Deliverables of Commissioning Authority

5.      You would be able to access the entire set of documents at www.ehss.ae under the green building department section

Query

With ref to the subject project there are few non-compliances areas in ground and mezzanine floor to meet the Fresh air requirements as per GB regulations.  We have attached HVAC floor plan for your reference. Kindly note fresh air cannot be provided in red highlighted areas as there is three side curtain glass for the external wall. Client had instructed earlier not to make any opening in curtain glass to keep the building aesthetic perspective. In other areas, Fresh air is provided by fresh air louvers with sand filter following the Design submission made for EHS NOC-BP.

In this regard, I would request you to give soft approach for non-compliance areas. If needed, we can arrange for the meeting as per your suitable time to explain the further construction complication to provide the fresh air for non-compliance areas. Your guidance will be highly appreciated  to proceed for further step. Please revert, if you need any further assistance..

EHS Response / Interpretation

 Further to your query we have reviewed your details and would like to bring the following to your attention

  1. The drawing shows that here are significant areas where you are seeking  clearance for non-compliance
  2. Fresh Air has been stipulated in the regulation for ensuring  acceptable  indoor air quality  and in that context gains importance for a large facility such as this
  3. We do agree that opening  the façade / curtain wall  may be objectionable to the client. However we have to explore other ways if required ducted system for introducing fresh air into the occupied spaces. Sand trap louvers are not the only means for fresh air.  Given that this credit has been well reviewed and approved, it is not prudent to completely  remove fresh air from such a large space. This will not be a health design.
  4. Accordingly we ask you to discuss with the MEP design team to work out  the most appropriate system that ensures adequate fresh air to the  space

Query

We are working in a residential/hotel project, the owner declared the building as a non-smoking building, do we still need a Blower door test? As per LEED, IEQ Pre2 - Option 1 - which is applicable for all projects : if we prohibit smoking in the building, then we don't need blower door test.

Reference below:

IEQ Prerequisite 2: Environmental Tobacco Smoke (ETS) Control

OPTION 1

Prohibit smoking in the building.

Prohibit on-property smoking within 25 feet (8 meters) of entries, outdoor air intakes and operable windows.

Provide signage to allow smoking in designated areas, prohibit smoking in designated areas or prohibit smoking on the entire property.  

Please confirm our understanding. The contractor's green building consultant thinks that this test is mandatory in all cases.

EHS Response / Interpretation

Our broad interpretation on the basis of your mail is that if the development is 100% smoke free then the purpose behind the blower door test may not exist. However, if the common areas are the only areas where "No smoking" policy  is proposed to be  implemented, then all  preventive measures such as weather stripping, tight enclosures including door blower test to prevent escape  / leakage of ETS  to common areas as well as adjacent areas have to be fully undertaken. In your project comprising residential and hotel, the challenge of effectively implementing 100% smoke free policy is enormous especially residential area. How exactly and effectively the policy is going to be implemented is also important. . Please review this in the light of your project and take the correct approach

Query

Our MEP Consultant's cooling load calculation considers the maximum allowed U-value based on Dubai Green building specs in order to provide flexibility in the design.  It is expected that the actual U-values on site will be different from the design/specified U-values.  The cooling load is valid as long as the U-value inputs are more stringent that the actual U-values. Due to this reason, we have used a less stringent U value in our heat load calculation.  Is it acceptable?

EHS Response / Interpretation

The purpose in having a robust envelope (stringent U values…) is to  use them in the heat load estimation and derive benefits in terms of reduced cooling loads and perhaps reduced equipment sizes as well. There should be consistency between the envelope values, wall  (facade)sections and heat load inputs . We do not understand your statement "flexibility in design U values" and that "actual U-values on site will be different from the design/specified U-values" .  It is not advisable to have different envelope values for different entities such as , one for heat load estimation and one for   site-level implementation. It brings confusion and administration challenges. Hence you are advised to ascertain the actual values proposed to be used in the project and use those values for the heat load calculation

Query

We are currently working on a shopping mall project which is typically a core & shell building. As per current EHS regulations this falls under in LEED (New Construction) category. We are facing certain issues in terms of implementing LEED NC rating system and we are of the view that LEED CS system would better suit the project. However, we intend to seek your guidance on this matter in order to proceed.

In general can we follow the LEED CS rating system for the project? If yes then which credits would be mandatory to comply with?

The project should target 22% (6 Points, LEED NC) OR 18% (6 Points, LEED CS) energy cost savings under EAp1: Optimize Energy Performance credit. It is difficult to improve upon energy performance of core & shell developments in comparison to other buildings.

Your early response will be highly appreciated.

EHS Response / Interpretation

Further to your mail, please note that EHS regulation is broadly aligned to NC. Having said  that if your project is CS, you would still need to follow the regulations. Having said that we would like to know the areas where it is impractical when  applying NC and the reasons. We would review and then advice you on whether to follow NC, CS or an alternative compliance path.

Query

We are currently working on a a core & shell building where we appear to have some challenges as detailed in the attached table. Would appreciate your assistance

EHS Response / Interpretation

Further to your query please find attached the table with our approach / interpretation

 

CreditReasons for not achieving compliance   Recommended Approach
EAc1: Optimize Energy Performance

The project consists of retail areas primarily and lighting and HVAC fittings shall be under scope of tenant. Owner's scope is limited to provide main supply for electrical works and mechanical works along with the central chillier plant and Air Handling Units etc.

For energy simulation, electrical & mechanical load has to be considered same for tenant spaces in both baseline and proposed case. This results in less energy savings comparatively and makes it difficult to achieve EHS Mandatory 22% energy cost savings in most of the cases.

Step-1

Carry out the energy modelling as per Core & Shell and determine the energy optimization achieved with the best ECMs (active and passive designs). Submit to EHS. We do agree that due to Mech / Elec loads being the same in tenant occupied areas, for base and design, the optimisation achieved would be lesser. Submit the energy modelling report

Step-2

Carry out the energy modelling as per New Construction (as though the owner is providing the whole scope i.e.HVAC / light fittings)  to confirm that the project is achieving the right optimisation in case it had been NC. Submit the energy modelling report

Step-3

All important requirements for the tenant occupied areas (which you would have considered for modelling under NC conditions must be clearly specified  in the  tenancy fit out manual  and demonstrated through

  1.  Relevant clauses of the tenancy fit out manual
  2. Relevant clause of the Lease agreement
  3. Undertaking from the client

Follow all the 3 steps

IEQc3.2: Construction IAQ Management; Before OccupancyInstallation of mechanical systems for tenant spaces doesn't fall under owner's scope except ductwork provision. Interior work in the tenant spaces, including HVAC systems fit outs remains unfinished until the space is handed over to the tenant.

All the requirements  of the areas that do not come under owner scope should be very clearly highlighted in the  tenancy fit out manual  and demonstrated to EHS by submitting

  1. Relevant clauses of the tenancy fit out manual
  2. Relevant clause of the Lease agreement
  3. Undertaking from the client
IEQc6.1: Controllability of Systems; LightingInstallation of electrical systems fit outs for tenant spaces, including controls, doesn't fall under owner's scope. Hence it is not possible to achieve this credit.Same as above
IEQc6.2: Controllability of Systems; Thermal ComfortAlthough this credit is not mandatory by EHS but still installation of mechanical systems fit outs for tenant spaces doesn't fall under owner's scope. Furthermore, occupant type/category for each tenant space is unknown. In such a scenario it is difficult to comply with credit requirements

You have to discuss with the owner, identify the possible cases and incorporate the requirements into the tenancy fit out manual.

This should be and demonstrated to EHS by submitting

  1. Relevant clauses of the tenancy fit out manual
  2. Relevant clause of the Lease agreement
  3. Undertaking from the client
IEQc7.1: Thermal Comfort; DesignInstallation of mechanical systems for tenant spaces doesn't fall under owner's scope except ductwork. This doesn't allow meeting credit requirements as interior work for tenant spaces is not finished.
  1. State the requirements in clear terms in the fit-out manual and submit
  2. Relevant clauses of the tenancy fit out manual
  3. Relevant clause of the Lease agreement
  4. Undertaking from the client
IEQc7.2: Thermal Comfort; VerificationCompliance to this credit is contingent to IEQc7.1: Thermal Comfort Design.

 

Query

We are the Green building consultant for a proposed shopping mall in  Dubai, which is currently under design.

The façade architect wants to know if there is any requirement for Visible light transmittance (VLT) for skylights. They want to put a low VLT skylight to minimize glare and too much brightness in the mall. SHGC and U-value of the proposed skylight is excellent much below the ASHRAE levels. Since our project is "Commercial" type, we do not follow the prescriptive approach, rather we follow the GB 4.0 regulations of EHS which is performance based. We perform energy modeling to demonstrate compliance to the energy efficiency performance requirements of EHS. Moreover, daylighting (IEQc8.1) in EHS' GB.4.0 regulations is not a mandatory requirement. Attached is the technical data.

Please let us know if there if there is VLT requirement for skylights/glazing as a mandatory requirement.

EHS Response / Interpretation

Further to your query, given that you are following GB 4 that is aligned to LEED, the performance based  approach as established by energy modelling would prevail. Hence you may proceed with energy modelling as per the requirements. Having said that a higher VLT obviously plays an important role in bringing the daylight into the facility and we would strongly suggest you to maximise tis passive approach as much as you can without of course introducing glare


October 2015

Query

On the villa regulations, we have the following queries

The below are mentioned as "mandatory" items; the use of:

    1. Solar water heating technology
    2. Energy sub metering (separate metering facilities for AC, lighting, power, etc..)
    3. Motion sensors for internal lighting devices
    4. Thermal imaging technique using high tech infra-red camera

Moreover, we noticed some other items, which seem to be not applicable especially for up to 3 floors villa/townhouses such as: sustainable site and management, Heat Island effect non-roof, recycling facility, EER energy efficient AC equipment, etc. Can you please clarify?

EHS Response / Interpretation

All points  (a,b,c,d ) you have mentioned are extremely important for operational  sustainability / energy reductions which are the corner stones of UAE and the Dubai supreme council of energy as well.  These serious commitments cannot be underestimated.  The regulation also acknowledges that for some type of developments, a specific requirement (such as motion sensor) may not be applicable. That is the reason you may find the wording "where applicable" which allows the consultant to address those specifically to his/her project.  It is important for the consultant to understand then apply

Query

We would like to seek your advise if only standard simplified version of EHS requirements can be announced as one page or so to be complied with by consultants only for villas and/or townhouses

EHS Response / Interpretation

The prescriptive Regulation is the simplest one where every aspect is explained clearly so that a competent and knowledgeable engineering consultant can comply (without engaging the services of a green building consultant) This has been in vogue since 2011 and all the consultants have become completely familiar with this regulation. A serious and sincere green building regulation has to comprise all the sustainability categories and so the entire process cannot be reduced to a single page checklist

Query

Can we apply GB 7.0 for villas which are less than 500m2 built up area?

EHS Response / Interpretation

Further to your mail, please follow Regulation GB 8 (which is exclusively for villa developments) along with its associated procedures

Query

We are writing this email to confirm if our warehouse project needs green building certification or not.

We have 1,500 sq meter of storage area which does not have any office and no air conditioning.Building is permanently opened from both sides (it is not enclosed space) and project site do not contain any kind of vegetation. We believe our project falls under Category 6 of EHS selection chart which may not need certification but requires prior Green building department approval. Please find attached drawings for your review and advise us accordingly

EHS Response / Interpretation

Further to the above please follow Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments and comply with the relevant sections of the regulation. A full-fledged submission is required at NOC-BP phase and BOC-BCC phase for which you may review submission procedures available in our portal i.e. EHS-GBP-11 and EHS-GBP-12.

In addition the required stakeholders (the consultant and the contractor)  should get accredited for the "Regulatory Awareness Program – Warehouse Regulations", a one day program conducted by the Green Building Department.  Please refer the MAIN CIRCULAR and the FOLLOW-UP CIRCULAR

Certification is not applicable to this project


August 2015

Query

We would like to gain clarity on the compliance requirements for of Heat Island effect-  Non Roof Component- Covered Car Parking. Please note that client want to have  covered car parking  with Steel Grey colour fabric having SRI value 15. The SRI certificate Chart has been attached for your kind reference. Based on the above, we request your office to provide us some suitable time to meet and discuss the issue. Looking forward to your usual cooperation and support.

EHS Response / Interpretation

Please note that  SRI is an important consideration for the green building compliance and the non-compliance  is in-principle not acceptable. We have so far not met up with any barriers to the adoption of this regulation and are unable to understand as to why you are facing a challenge. While we respect the client's right to preference any specific colour shade, we should bear in mind that the sustainability criteria are not compromised. We are attaching a generalised shade card that broadly relates the shade to the SRI values. We suggest that you take up this subject with more suppliers and are confident that you would be able to achieve the SRI without compromising the client's needs.

Query

Reference to the above mentioned project, please be informed that client want to have some  of mixer  which contain higher flow rate than 6l/m at 4.14bar pressure as mentioned in the EHS Green Building Regulations.  Hence, We are proposing to provide flow restrictors (technical data sheet attached ) to comply the EHS Green building requirements for the minimum flow rates for the sanitary wares.

Furthermore, Project will be equipped with 3 No. self-closing ½" taps . The Self closing long taps,  meeting the client requirements, have flow rate 9L/M at 3 bar as per the data sheet while this flow rate to be at 4.14bar pressure. Kindly allow us to use the same to meet the project requirements.

EHS Response / Interpretation

Flow restrictors and arrestors are more commonly used as retrofit devices to achieve savings at minimised costs. Having said that, if the supplier is unable to provide the required flow rate , you may resort to an alternative compliance path in order while at the same time catering to client's preferences. This is under the condition that you would be able to achieve the required flow rates for the mixers and taps consistently. An element of awareness and training on these externally added restrictors would also be required to be given to the maintenance team


June 2015

Query

One of my friend is constructing warehouse in TECHNO PARK and I need a clarification for internal painting whether it is mandatory to have FIRE PROOF PAINTING or we can do normal low emitting paint.

EHS Response / Interpretation

Please note that the requirements of the paints from the indoor air quality and green building point of view are well explained in our Green Building Regulation. Your consultant would be well aware of it and we suggest that you obtain the details from them. We would further clarify that the fire proofing is not under the purview of green building.

Query

This is regarding test certificates that we have to submit during completion inspection for various items. My query is specifically regarding roof sheet SRI value certificate. I have attached test certificate as submitted to me by the contractor for a project that is under construction. Will this certificate be accepted?

EHS Response / Interpretation

Further to  your mail please be advised that the test certificates are acceptable. However you should exercise caution  to ensure that the test certificate is genuine and reflects the specific product / system used in the project. We are however unable to comment on this particular certificate you have attached owing to lack of information. It is advisable to submit a certificate that relates to a project

Query

We are currently working on addition of the office to the existing facility in the Jafza.  The addition is the proposed Ground Floor with area of 363.46 Sqm and the Mezzanine Area of 363.46 Sqm with total BUA of 726 sqm. Please advise on the following,

  1. From the GBP-03, we understood that applicable certification level is Cat 3 and should follow GB-4.0 with USGBC and EHS certification as Optional. Please advise if this is correct.
  2. Please advise if the consultant registration with EHS is mandatory? Can we submit to EHS if our staffs have capabilities to compile the documents? 
  3. If Point 1 & 2 is incorrect, then please advise if Regulation GB-6 can be applied to the project? As the project is the addition to the Warehouse, so most of the GB-6 Regulations might be relevant to the new construction. Is it acceptable by EHS?

Drawings have been attached to this email for your reference.

EHS Response / Interpretation

Further to your mail, please find point wise response as below

  1. Your point -1.  Please follow the regulation GB-6  "Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments"
  2. Not necessary. Any competent AEC / Engineer of record can make the submission. However you should have undertaken the accreditation given by EHS to consultants exclusively on this regulation. You may contact the accreditation department at 8068866
  3. Yes. As explained in point 1 and 2 above.

 

April 2015

Query

We are of the opinion that CO2 sensors would go well with the projects incorporating DCV. Hence it has not been incorporated in this project. Trust this is acceptable

EHS Response / Interpretation

The intent of the credit requires the consideration of  CO2 sensors in the breathing zones of  densely occupied spaces within the development. An alarm in the event of unacceptable levels of CO2 (say for e.g. more than 1000ppm ) in the spaces would alert the operators on the likelihood of poor IAQ in that particular zone using which they may resort to any of the operational adjustments.

We do agree that the concept of DCV is  appropriate in cases of extremely varying / fluctuating occupancies that are typical of certain categories / end uses. However the point of our report is  to ensure that the intent of the credit is met by having the sensor and the alarming system in place with several simple and practical strategies which need not be considered complex.

 

March 2015

Query

We are currently looking into a project that falls under the EHS Trakhees jurisdiction. The project is a container terminal at a port. It mainly comprises of substations (a few of which include a small office space), demountable buildings (which are assumed to be temporary office spaces – will be confirmed), and workshop and storage spaces. Please see attached a partial site layout and a typical substation layout for your reference.

After reviewing the available documentation on the Trakhees website, it is understood that this project should adhere to the Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments in order for the project to receive an EHS NOC - BP to facilitate the building permit, and a NOC-BCC at the end of construction. This will include the team undertaking the necessary "Regulatory Awareness Program – Warehouse Regulations" that is conducted by the Green Building Department. However, it is not clear whether the substations need also follow the regulations; perhaps only the habitable spaces? Also, will the function of the demountable buildings affect which regulations needs to be followed for this project?

EHS Response / Interpretation

Further to the above please follow the Prescriptive path for the substation as well to the extent they are applicable as it would have impact on the net energy intensity (AC loads especially)  of the building.

Temporary buildings are generally excluded but please confirm with the details to enable us to review and offer our interpretation

Query

I am hoping to get confirmation from you that the EHS LEED credit EACr2 is not mandatory. I've heard speak that it once was, but no longer is. The document 'Regulation GB –4.0 Green Building Regulations (LEED-NC-v3.0)' on your website corroborates the non-mandatory status (attached below), but it would provide me with peace of mind to get your confirmation if you don't mind too.

EHS Response / Interpretation

Further to your query we would like to clarity that on- renewable technologies were brought under voluntary  bracket to enable the stakeholders to assess the genuine needs of the situation and adopt suitable technologies that would add value to the project besides reducing the reliance on grid power. The mandatory nature of the regulation was relinquished  to avoid situations such as "Green washing"  where developers started embracing them even when situations did not appear to require them.  Having said that, we continue to very strongly encourage the stakeholders to adopt them wherever the situation demands and demonstrate their initiative in appropriate areas that are best governed by the project needs. This is the only way we collectively can support the DIES, which is the broader initiative of Dubai government under the supreme council of Energy.

Specific to your project, please use the above as guiding principle and work towards having a mix that genuinely helps the project . It may be solar thermal, solar PV or any others . An integrated design approach would clearly provide the pointers for this. However you may not be bound to reach the specific %age. A complete In-principle Waiver on this credit  should not be anticipated by the team.

 

February 2015

Query

It is our first time to submit green building NOC it will be a big help for us if we can ask for a sample document or format on how to present the documents complying the comments.  Thank you for your support

EHS Response / Interpretation

Further to your query please be advised that we do not have any standard format. More than the format it is the content / demonstration of the compliance to the  green building regulation that is more important. Please make sure that you are understanding the requirements of the regulation and complying with them in your designs.  The evidence required to be submitted in the submission is clearly mentioned in a separate column in our regulation, which you should follow. All these supporting  documents can then be segregated into appropriate folders and subfolders (for categories and sub categories respectively) and  then submitted

Query

For our upcoming project, we need will be needing the specifications for glass and aluminum.In line with this, we are requesting your good office to give us details about your specifications for glass and aluminium in that way we can also make preparation on our end.

EHS Response / Interpretation

Further to your email please be advised that the sustainability department does not provide any specification for the materials that you requested. The department's Green Building regulations do stipulate certain thermal characteristics for the composite envelope (all elements out together) and as engineering consultants it is within your purview to  identify the right sections to achieve the intended values. You shall refer the respective green building regulation for those values.

Query

We have project, wherein the client is adding workshop of 4,618 Sqm to their existing facility. Please see attached the setting out plan. Our query is regarding the applicability of Regulations.

As there are no conditioned areas, so the applicability regulations we are presuming is Regulations 7. If not, then provide us the guidance on the regulations applicable. We are about to start the design process, so please confirm the applicable regulations to integrate the requirements

EHS Response / Interpretation

 You are asked to follow GB-6.0 – EHS Green Building regulations for Warehouses and Industrial developments for your project. Please follow the procedure EHS-GBP-11, Client Procedure for Green Building Submissions during EHS-NOC Building Permit (NOC-BP) (Warehouse & Industrial Developments) in order to understand the submission requirements for projects following this regulation.

As part of the above, please submit the GBF forms duly filled

The submission should be complete with all the supporting documents as prescribed in the Regulation GB-6.0 with proper segregation and arrangement of folders for various items in the respective category of the regulation. Please refer to the portal www.ehss.ae for downloading the regulations, forms and the procedure.

Please be informed that a green building review fee of AED 1 per sq.mt is applicable for the project.

Query

I appreciate if you could assist us regarding use of Horse Shoe Heat Pipe for 100% outside air Kitchen Make up air unit for our project  located in Palm Jumeirah. Is there any particular requirement from Trakhees?  

EHS Response / Interpretation

Please be advised that EHS does not have any specific requirements regarding the use of Heat Pipes. You may however check with the Civil Engineering Department (CED) which has some requirements surrounding the HVAC

 

January 2015

Query

We write to you in reference to an upcoming project in Jumeirah Village Circle.  A supplier has proposed to us their product to be utilised in the project. However, we would like to know if this particular product, with the claimed U-values, can be applicable for the project. The dropbox link provided at the bottom is also active. Your insight in this matter is highly appreciable.

EHS Response / Interpretation

Further to your email please be advised that the sustainability department does not prequalify / approve any material. The department's Green Building regulations do stipulate certain thermal characteristics for the composite envelope (all elements out together) and as engineering consultants it is within your purview to  identify the right sections to achieve the intended values.

You may however try contacting the civil engineering department (CED) to check their concerns if any on the material.

Query

We are currently in touch with a client who is planning to construct a 12,000.00 sq-mtr residential building in JVC. From what I understood by reading GBP-03, this facility falls under Cat 2 and Green Certification is mandatory. I have read all documentation relating to the LEED NC and would appreciate your reply to the following:

If we are to take the path of certification through USGBC (not EHS in-house certification), do we still have to be registered with EHS Trakhees as a "Green Building Consultant" and/or "Commissioning Specialist"?

EHS Response / Interpretation

Yes. Irrespective of the certification option pursued, the administration of the project (submissions to EHS for NOC-BP, NOC-BCC, site management, and all the other works involved in the project to comply with the regulation ) should be through a prequalified specialist.


December 2014

Query

We are studying the location of the Co2 sensors and whether it's better to keep it in the breathing zone (between 3 and 6 feet) of the densely occupied spaces (as per LEED) or to locate it in the return ducts "each space has a separate dedicated duct", would that be acceptable by EHS?

EHS Response / Interpretation

Given that the regulation is aligned to LEED, we would suggest that the sensors be located and installed in line with the requirements of the LEED. Having said that we would also add that the purpose of the said sensor is to assess the CO2 levels in the occupies ZONE accurately and accordingly provide the required signal for appropriate action such as triggering an alarm, demand controlled ventilation (DCV) for energy conservation etc.

A sensor's location should facilitate the representative readings of the concentrations in each major occupied zone. Depending on the size of the area, providing multiple sensors may yield better information than having a single sensor. For such cases, the sensors should be located in the occupied zone. Also care must be taken to confirm that  the sensor is not located in a place  where people might regularly breathe directly into the sensor. These were the reasons that led to the adoption and recommendation of a practice where sensors were placed 4-6 Feet above the floor.

Although there have been discussions / arguments in support of  sensors being located in plenum / return duct, they may be rendered ineffective under certain circumstances.

  1. The readings may be incorrect / lower (than what is actually occurring in the place) in case of a leaky supply air duct which will dilute CO2 levels concentrations in the plenum.
  2. In case of return air ducts serving multiple zone situations, CO2 levels measured will reflect an average of conditions in all spaces. This may actually reflect a situation where  some spaces could be highly under ventilated, and others over ventilated. Typical ventilation design practice requires the system to provide ventilation to specific zones based on their actual or design occupancy. A Common return air sensing may defeat this purpose

To conclude we would like to advise you that our green building regulations specify the required criteria and the strategies. However, it would be the responsibility of the stakeholders to undertake the works in such a manner as to accomplish the objective of the regulation. Our above interpretation purely supports this position 

 

November 2014

Query

We would like to have your opinion / confirmation on the type of panels to be used for the wall and roof assemblies for our proposed warehouse project. We have attached the technical data sheets for the 2 options that we are contemplating to use. One is of 50mm thickness and the other being 75mm

EHS Response / Interpretation

Further to your mail with the attachments on the subject, please be advised as under:

  1. EHS Sustainability department does not have any specific requirements on the choice of materials / sub-assemblies for the envelope which includes wall, roof, glazing / fenestration, skylights etc. Neither does it approve specific products / systems to be used in the project.
  2. We do have specific thermal properties called for in the regulation which are available in the Table-1 of Annexure of the Green Building Regulation GB-6.
  3. In addition we have also developed a Guideline for Envelope compliance which is available in the Guideline section of the portal. This is to assist the stakeholders with various possibilities.
  4. You may feel free to choose any of the systems that comply with the required U values. You should however ensure that the used product / system get the required approval / clearance from other departments such as CED where applicable.

We have also briefly reviewed the technical datasheets and prima facie it appears that note that only 75 mm insulation seem to be closer to the requirements for roof / wall. This is purely our informal interpretation and should not be deemed a clearance to proceed further

Query

Per EHS GB regulation, the skylight specification requirement is 1.9 W/m2.K, SHGC – 0.174 & VLT -40%. The maximum achievable specification with triple skin skylight panels is 1.9 W/m2.K , SHGC – 0.56 & VLT – 50-60%. The double skin skylight panel specification is 2.15 W/m2.K, SHGC – 0.61 & VLT -60-70%.

As you can note from the specifications that even with the use of triple skin skylight panels, the SHGC values is not able to meet the EHS GB requirements. Also, the specification difference between triple & double skin skylight is very minimum. However, the cost difference between the two is significantly higher. Considering these minimum differences in specifications, higher cost differences and the fact that the skylight would be used only for non-air conditioned spaces, please advise if the project can pursue with double skin skylight panels.

EHS Response / Interpretation

We have reviewed your below request. Taking into consideration that the project is non-air-conditioned, we are of the opinion that you may proceed with the double skin panels for this project.

Query

One of our Hotel projects was issued with  Building Permit on 19th December 2006 and the Revalidation of Building Permit  was done on 28th May 2014, along with Amendment on 5th April 2009. We believe that the EHS Green Building Regulations and In-House Certification for the same, do not apply for the above mentioned project as the Building Permit was issued before January 2008.Furthermore, the project team and the client would like to confirm the same from EHS. Kindly advice.

EHS Response / Interpretation

Further to the above, we note that the original building permit was issued 2006 and revalidated in the recent past. EHS Green Building Regulations have been in force since 2008. Hence it is not applicable to this project. 


September 2014

Query

We have a project in JAFZA (WAREHOUSE & OFFICE  that comprises of office and warehouse with a total built up area of 228,602.46 Square feet. The project received EHS building permit in 2008 for LEED NC v2.2 certification but the project's construction was put on hold after obtaining building permit. Since the construction on the project started up again, the client has expressed the desire to certify the project under EHS GB.6 certification instead.

I have attached the feasibility report that was submitted at the BP stage. I hope that these documents will be sufficient for you to get an overview of the project and await your guidance on whether this project can switch to the EHS GB 6.0 certification. 

EHS Response / Interpretation

We have reviewed your letter and would like to state that it is not possible or pertinent to change the regulation that has already been committed by the stakeholder earlier on in the project (in this case year 2008 before obtaining the building permit). We presume that the project is already up in running and has so far complied with the LEED based regulation as per the original commitment. Under these considerations, the project has to continue with the original regulation

However if this project is yet to practically commence the construction,  you may proceed with a fresh NOC-BP submission for the Green Buildings as per the submission procedure. The department would undertake the review and respond appropriately'

Query

We have an enquiry from one of the Consultants regarding a 'New Toilet Facility building' of 30m2. This project comes under EHS Jurisdiction and so we would like to know if this facility will have to follow any regulation. We are a bit confused regarding this project as the built-up area is really small. I would really appreciate if you could revert with your feedback on the same

EHS Response / Interpretation

Further to the above, we have reviewed your query and would like to state that  the proposed facility amounting to 30 sq.m is small. There is no need to formally make a Green Building submission or a Green Building Project Plan GBPP. However you are encouraged to follow the prescriptive compliance path as applicable for this project as a means to demonstrate the commitment and communicate sustainability.

Query

I wanted to know if we also need a green building consultant during the construction stage of the project ( for the buildings above G+3)  or can we just have them during the design stage. Please confirm if we can include the scope of the green building consultant only during the design stage or design AND construction stage

EHS Response / Interpretation

We have reviewed your query and would like to advise you that the role of Green Building consultant is required at all the stages upto the completion and handing over. This includes BCC submissions as well which has to be handled by the same consultant

Query

We request you to please resolve a query for one small project in JAFZA .Please note that the total cooling area in the project is very less (around 175 m² only) & the total built up area is around 6,000 m² only. Kindly confirm if green requirements can be waived off for this project except selection of ozone friendly AC units in HVAC system & achieving minimum LPD requirements in Electrical system.

EHS Response / Interpretation

Further to your query please note that Green Building regulations are mandatory and cannot be waived off. Please follow the following documents which are available in our portal www.ehss.ae

  1. Regulation GB- 6.0 Trakhees - EHS Green Building Regulations - Warehouses and Industrial Developments
  2. EHS-GBP-11 Procedure for NOC-BP Green Building Submission (Warehouse & Industrial)

Query

I have been trying really hard to convince my management that they need to hire a green building consultant to get on board for the buildings and the villas can be done in-house. Can you please confirm once more if a green building consultant is required for the list companies or can it also be done in-house?

EHS Response / Interpretation

Further to your mail, please follow refer our procedure EHS-GBP-03  to understand the full requirements. It clearly highlights the strategies to be adopted for the projects falling into different categories and it addresses the subject of green building consultants as well.

Query

We hereby seek for your general guidance on practicality of literally implementing EHS or LEED Green Building guidelines as stipulated word by word within the regulations concerning Materials and Waste Management. In a practical sense, EHS have been very efficient in understanding restrictions during all our submissions and previous experience with EHS and LEED submissions.

However, in the case of "text book type" implementation strategy, it becomes an obstacle wherein that is humanly impossible to track ,source and verify and further provide documentary evidence by going to exhaustive lengths to interrogate and police suppliers and vendors that run into a quantity several hundreds or even thousands of submittals. In this case, EHS and LEED submissions are compiled based on rule of thumb calculation in percentage that is acceptable as a summary breakdown that is further substantiated by providing official letters from the suppliers.

 

Recycled Content and Regional Materials

Documents submitted to EHS/ LEEDMaterials Manual
Material Inventory Sheet including all construction materials, costing and % of recycled content/ recycled material in each material.
Manufacturer's cut sheets/ letters mentioning recycled content in the materials.
Guideline Requirement -"Text book case"Material Tracking Sheet (monthly) including all construction materials, costing and % of recycled content/ recycled material in each material. Sheet to include delivery note numbers and receipt numbers corresponding to each material
Material Inventory Sheet (summary) including all construction materials, costing and % of recycled content/ recycled material in each material. Sheet to include delivery note numbers and receipt numbers corresponding to each material
Delivery notes including % of recycled content/ recycled material of procured material and manufacturer's letter confirming the same
Receipts of all materials procured on site to verify costs.

 

EHS Response / Interpretation

We do acknowledge the challenges here in administering these credit a large part of it owing to the limited infrastructure and awareness on the subject as well. At the same time, we should not draw solace from these circumstances to completely circumvent the minimum requirements needed to demonstrate adherence to the credits.

  1. In the most condensed version this credit requires project materials cost, tabulation of the materials being tracked for recycled contents and a narrative (optional) for explaining the approach.
  2. This no doubt imposes some strict requirements on the calculations (exact percentages) of the recycled content materials used in the project using reliable and verifiable sources.
  3. It is in point no 2 that we expect genuine and practical approach which adequately demonstrates the compliance and can stand testimony to 3rd party independent audit. At the same time, we do not want the stakeholders to start chasing papers when it could be handled in a more logical way, without compromising the integrity.
  4. Please note that the experience and the expertise of the stakeholders have a major role in this and it is not possible to prescribe a universal path for this credit. It may vary for different materials being used in the project; some of them requiring additional documentation to check the veracity while few most common items may be taken at the face value based on published documents e.g. steel.
  5. You may always use the narrative for explaining any unique circumstances or approach
  6. We suggest that you follow the prescribed established path as basis, take a practical / sincere approach for materials / systems having challenges (in coordination with other stakeholders including EHS) and track the progress as the project moves. This would be the basis to ascertain if the project is eligible for this credit.  Irrespective of the outcome, this approach gives all the stakeholders an assurance and satisfaction that the team has pursued sustainability with true intentions and spirit.  

 

Construction Waste Management

 DocumentsConcerns
Documents submitted to EHS/ LEEDConstruction Waste Management PlanConstruction waste diversion of 50% of total waste EHS Mandatory
Construction waste calculation sheetNon-availability of required recycling facilities within region
Delivery notes/gate passes from haulersWaste segregated on site being disposed from site by loading different wastes in same truck by the hauler
Guideline Requirement -"Text book case"Chain of handling/ recycling - letters from haulers after waste taken away from site 

 In the above case, we are submitting DM delivery notes and Vendor delivery receipts that are usually accepted by EHS. However, due to local restrictions, it is not possible to substantiate and provide backup documents expect pickup receipt and delivery notes

EHS Response / Interpretation

  1. This credit requires you to create a well thought out table that summarizes the different types of waste being diverted from the site and an explanation of how these are being diverted with the details of the agents. This requires a good level of open discussions amongst the stakeholders including the recyclers. You have to work out a correct methodology to estimate the actual items being diverted and provide the evidence.
  2. It should be noted that while chasing the documents is not the intent, a robust mechanism should be in place to give the confidence and assurance that the values provided are true indicators of the diverted materials.
  3. If there is a genuine concern that the materials cannot be diverted from landfill, document it with adequate proof in which case it is not advisable to pursue it at all.   
  4. Although these are construction phase credits, planning of this start well at the design stage.

Query

We are working on a new project in your jurisdiction. As per EHS-GBP-03, we fall under CAT-2, which means we can go for either certification (LEED 2009 or EHS In-house), please confirm our understanding. Also, if we decided to go for LEED will our BCC NOC face the risk of being delayed till USGBC finish their review?

EHS Response / Interpretation

Further to your mail, please be advised that the client has the option either to pursue LEED or EHS In-House certification. EHS commenced this In-House service early 2012 to provide specific benefits and value additions to the project and the stakeholders.

We would also like to clarify that NOC-BCC would be issued after review of the submissions. However generally it would not be linked to certification be it LEED or In-house given that some credits can be accomplished only after permanent power and that permanent power connections can be obtained only after BCC. 


June 2014.

Query

We are writing you to ask clarification related to the minimum points to be achieved for EHS Green Building certification, under Version GB 4.0. As per Green Building Regulation GB 5.0 (LEED-NC v2.2), the minimum points to be achieved is 32 points, which is the maximum point for achieving LEED at Certified level.

 

Similarly, are we correct to assume that under Green Building Regulation GB 4.0 (LEED-NC v3.0), the minimum points to be achieved is 49 points as this is the maximum point for LEED at Certified level?

EHS Response / Interpretation

Further to your query please be advised that the minimum mandatory points are 38; however the project should seek additional points so as to achieve the minimum CERTIFIED level which is 40 points. Details of the mandatory points are as per the link http://www.ehss.ae/forms/ehsgreenbuildingregulationsmandatorypoints(forprojectsfollowingleedv3).pdf

 

May 2014.

Query

Could you please guide us through the procedure/ specifications to be following to achieve green building rating for interior fit-out refurbishment projects?

EHS Response / Interpretation

Further to your query please be advised that we do not have specific mandatory regulations for interior fit outs. The Green Building Regulations for New Constructions are available in the portal www.ehss.ae . The Main Regulations are GB 4, 5, 6, 7 and. Please review them in the light of your project and should you need any clarifications, please do not hesitate to contact the department.

 

April 2014.

Query

With ref to an upcoming project, we need a clarification on implementing daylight dimming control and motion sensors for warehouse area. During the design Submissions, the project had included the day light dimming controls (D-5) and motion sensors (D-4) for the warehouse area. The client wishes to reconsider the inclusion of daylight dimming controls, as the motion sensors are already included, which would control the lights installed in complete warehouse area. The warehouse would use for material storage purpose only. Hence in this case, is it feasible to provide two types of controls for the same zone? Can we exclude the dimming control for warehouse area as motion sensors are already placed?

EHS Response / Interpretation

Further to your mail please be advised as under:

  1. D4 was meant to be used in RELEVANT and APPLICABLE areas (such as pantry, conference, long passage etc.) to avoid operation of internal lighting devices when not needed, thereby saving electrical energy.
  2. D5 (for warehouses larger than 2000 sq.m) on the other hand is to maximize the use of daylight and resort to artificial electrical lighting only when the former is not able to adequately cater to the internal needs. This assumes that daylighting initiative is already put in place within the project. In your specific case, if there is adequate daylighting in the area, the lights need not operate even if there is occupancy. In other words, the daylight harvester would recognize the signal from the occupancy sensor and switch on the electrical system ONLY if daylight is insufficient. We believe this is the right logic
  3. This is our interpretation based on your specific case and you may consider it accordingly.

Query

This is with regards to the specific credit requirement and the concerned letter/template that is required to be submitted for EHS In House certification wherein the respective attached letter was verified by the client to contain US laws and specific requirements that are not realistic and reflective considering the nature of land acquiring process that is purely related to  commercial investment without much choice or consideration on the decision which is most common in developments in this region. We have attempted to justify the intent to the client and compliance status and further seek your advice on the way forward

EHS Response / Interpretation

Further to your mail on the subject, please be advised as under: 

  1. Given that the Green building regulation is aligned to LEED rating system, there is a necessity to adopt those broad principles while pursuing the credits. As you would agree, several elements of the regulation draw reference to international standards that are followed for energy efficiency, water efficiency, indoor environmental quality etc.
  2. However, we at EHS have always attached enormous importance to the sustainability criteria that addresses the needs of the region.
  3. In response to your specific query on site selection, we ask you to look into the intent behind the undertaking and provide an explanation of how it is met notwithstanding the limitations supposedly stated in the mail. The department would be able to review it and take an appropriate position.


February 2014.

Query

We would like to inquire about the information related to the Green Building Consultant registration process such as the following:

  1. The stages for registration process for green building consultancy.
  2. The possibility of carrying out an in-house Green Building study/ LEED certification for our own projects without appointing a 3rd party agency, knowing that we have a LEED AP BD+C Architect/ Design Manager.
  3. Some inquiries about in-house EHS certification for the Green Building.

EHS Response / Interpretation

Further to your mail on the subject, please be advised that the information that you are seeking is available in our portal www.ehss.ae . The related links are provided for your reference.

  1. Pre-Qualification
  2. In House Certification

Please note that projects following the LEED based rating system are required  to be administered by  any of the EHS prequalified green building consultants as explained in the  procedure procedure EHS-GBP-03.   

 

December 2013

Query

In regards to one of our projects, we have a query in regards to Indoor Environmental Quality Credit 6.2 (Controllability of Systems: Thermal Comfort) of LEED. The credit requires that the comfort controls for at least 50% of the occupants are installed. In the case of this Project, there are 96 private studios, no shared spaces except for the GYM on the roof, and all Core & Shell areas on the ground floor are excluded from this credit.

Please advise whether or not it is possible to pursue this credit knowing that AC units and their control will be installed in every residential apartment in the Project. Also, all corridors are exposed for natural ventilation and each apartment can also be naturally ventilated as it can be opened from both ends. For further info, the main lobby and the public toilets are also Air Conditioned.

EHS Response / Interpretation

Further to your query, please be advised as under:

  1. One control per unit is necessary.
  2. If you are trying to approach the credit through natural ventilation, please ensure that area of operable window meets the requirements of ASHRAE 62.1-2007, paragraph 5.1 for Natural Ventilation.
  3. Conditions for thermal comfort are as described in ASHRAE 55-2004, and is based on  air temperature, radiant temperature,  air speed,  humidity
  4. Multi occupant spaces also have to be included to facilitate adjustment to suit group needs

Under the above guidelines, you may pursue the credit. However as always please ensure that the LEED compliance requirements are adhered to given that the project is complying with that regulation although alternative certification path.

Query

We have two queries in regards to the Green Building Requirements for one of our projects and they pertain to sustainable site section. It is specified under credit 4.2 (Alternative Transportation: Bicycle Storage and Changing Rooms) that for Residential Projects: covered bike parking shall be provided for 15% of the occupants.

First of all this is to confirm that the building can be considered as case 2 (Residential Project) where bike racks are provided for the occupants but no changing rooms are dedicated for the public, since the building is mainly residential where only the GF is freed up for commercial use and the upper 4 floors serve as residential apartments constituting 96 Studios

Second, while we aim to provide parking for 15% of the occupants, this is to kindly ask if it would be possible to still pursue this credit without covering the bike parking, since none of the car parks are covered and this will entail additional external works, which might also lead to variation order from the contractor at this stage.  Our experiences around Dubai suggests that none of the bike parking locations are in covered spaces

EHS Response / Interpretation

Further to your mail, we would like to confirm that your understanding of the requirement of covered car parking is correct and is consistent with the requirement of LEED for residential buildings whereas this is not the credit requirement for other types of buildings. Secure and enclosed storage seems to be the norm.  This has been the trend globally for the residential buildings given that they are stored for extended periods of time and requires proper security and protection as well. Under these circumstances we would be constrained to keep up that consistency in line with the LEED interpretation. However if you have come across any CIR ruling that has taken a different approach, we would be able to consider it in our interpretation as well. We can also suggest that you explore the compliance options so that you are able to achieve the covered space criteria.

Your point on the public parking racks in Dubai is noted. However this case is different given that it is a residential project and attempting a specific LEED credit that has stipulated some requirements.

 

March 2013

Query

We are constructing the Additional Shed to our existing facility in JAFZA. Total area of the Proposed Additional shed is 1,688 Sqm and total conditioned area within the new construction is only 17.5 Sqm which is equals to 1% of the total built up area.  As per procedure "EHS-GBP-03 Procedure for Ascertaining EHS Green Building Regulations Applicability to a Project" our project falls under Category 3. As we are not aware that area mentioned in above regulation is referring to Total BUA or the conditioned area, so we are presuming to follow Prescriptive method which is "Regulation GB- 7.0 Green Building Regulation-Prescriptive Compliance Sheet" regulations. Hence we are requesting you to confirm the our approach is complying to EHS GB regulations or if in case it vary then please let us the correct approach.

EHS Response / Interpretation

Please note that you have to follow Regulation GB 6.0 for your project. The link is http://www.ehss.ae/forms/regulationgb6.0greenbuildingregulations. The category you have considered is incorrect. Your project would fall under Category-4.

 

January 2013

Query

Our project comprises Fit out Modification (in existing Ground and Mezzanine floors) and Guard Room. We note that during EHS NOC – BP submission, a commitment had been provided on carrying out Thermal imaging for envelope tightness during the construction stage. Kindly note that the proposed fit out modification is being carried out with existing building envelope, in the current facility. During construction, no modification of existing building envelope is envisaged. Hence, kindly request an advice on the requirements of thermal imaging for the project and if for this project, the requirement can be exempted from EHS NOC – BCC submissions.

EHS Response / Interpretation

Further to your mail, we do understand that the envelope already exists. However noting that HVAC units are proposed to be installed in this facility, it is essential to ensure that the conditioned air (and hence the energy) does not get wasted through the cracks / leakages in the envelope. This is the purpose why thermal imaging is prescribed.  It is recommended that it be carried out along important sections such as pipe/duct/sleeve penetrations, window / door frames (external) and other areas as felt essential for the project. In case minor cracks / leakages are noted, they may be rectified using suitable caulking compounds. Besides achieving the compliance, it would certainly save energy.

 

November 2012

Query

We request your clarification and guidance on a very common issue wherein a conditioned office would be located within an unconditioned warehouse. The only area of direct exposure to the outside would be one portion of office wall, however, the roof and other three sides will be located within the warehouse.

EHS Response / Interpretation

Considering that the office in question is Air conditioned, the regulations require them to comply with the envelope characteristics for conditioned areas. This is keeping in mind that the heat load calculations are going to use these values In the process of sizing the equipment. This is despite the fact that some walls are not exposed. We suggest that you run the heat load estimates for the offices for the 2 scenarios and submit it to us for formal interpretation and ruling

 

October 2012

Query

Our Project consists of 2 identical residential buildings (Studio Apartments – only). Each building has a total built up area of 8,000 sqm , with 96 studios and 4 typical floors. Accordingly  due to the small magnitude /scale of this Project and the short Time for Completion,  we would like to check and obtain your special approval ( if possible) for considering the said Project as "low rise residential buildings "and hence, submitting the GBPP under Category 1

 

EHS Response / Interpretation

Further to your mail please be advised that the categories of the project are based on international norms and the same have been applied for "Low Rise developments" as well which limits it to villas and 3 habitable stores. Accordingly it is not consistent or appropriate to bring your development under this category.

 

Hence we ask you to follow procedure GBP-3  as per the link reproduced below. Please note that for the certification of the project, you may opt for EHS In-House certification in place of external certification.


April  2012

Query

We  have 2 projects under design right now and needed your advice with regards to Green Building requirements for the same.

The first project is an office extension project. The client has an existing office touching his warehouse and intends to increase his current space. For this we are adding a 200sqm office space touching the existing office. Do we follow the latest Green Building regulations?

The second project is a warehouse extension project. The client has an existing warehouse and office building and wishes to extend his warehousing facility. The additional warehouse area is approximately 1,300sqm and the client will be installing racking system to store the material. Kindly advice as to what will  be the extent of Green Building regulations.

EHS Response / Interpretation

Further to your query, you are asked to follow Regulation GB 6.0 and apply the relevant components of the regulation for the 2 projects.