December 20, 2013 Re: Building Industry Coalitions Position on Regulating Building Reflectivity Dear Mayor Rawlings and

Dallas City Councilmembers: Recently, in response to a highly unique circumstance, a building code amendment was proposed in an attempt to regulate building reflectivity on a city-wide basis. After a thoughtful and sensitive dialogue among our industry peers, city officials and other interested stakeholders, we (the undersigned members of the Building Industry Coalition) continue to believe that regulation of building reflectivity through a building code amendment is inappropriate. Instead, the City of Dallas should rely on neighborhood-specific zoning regulations to address this issue - as already addressed in at least 30 of the citys planned development districts where reflectivity has been discussed, debated and approved based on the uniqueness and character of the neighborhood area (ie: PD 193, the Oak Lawn Special Purpose District). The City of Dallas has been a strong leader in creating appropriate regulations to protect the public good, and we believe that this local neighborhood assessment of reflectivity will serve the citizens better than a city-wide regulation that ignores the nuances of good community development. A building code provision that regulates reflectivity through a one-size-fits-all prescriptive path (i.e. a simple reflectivity percentage limit) would be unnecessarily restrictive. First, it would limit the selection of glass options to undesirable dark tinted or colored glass that could impact the aesthetic of our community. Additionally, this restriction would make it difficult to meet the energy code requirements because it would lessen the transmittance of desirable daylight through the glass. The result is an indoor space that is darker and increases the use of artificial lighting - thereby increasing the energy consumption of the building. Building code regulation through a performance path (ie: reflectivity analysis through software simulation) is too subjective, has no industry established thresholds, and is not yet capable of reliably proving compliance in actual built conditions. There are emerging software tools that help architects and their consultants optimize form and material selection to mitigate reflectivity concerns; however, industry accepted standards do not yet exist that quantitatively define acceptable thresholds of reflectivity, glare, and temperature differential or allowable time durations of each. More importantly, such thresholds should be dependent on the function of the neighboring buildings and the potential effect of the reflected daylight. These tools are also not yet quantitatively reliable in ensuring code compliance or in matching predicted results to actual constructed outcomes. The heightened awareness of reflectivity concerns in the Dallas area has, through natural market forces, incentivized commercial real estate developers, their equity and debt providers, and design professionals to perform their own due diligence on this highly subjective issue and to reasonably ensure the delivery of a socially, environmentally and economically successful market product. Reflectivity studies have been voluntarily commissioned by real estate

developers for recent projects, to aid in minimizing the negative impacts on surrounding properties and to ensure a successfully marketable product. We expect this trend to continue where appropriate, and for the individual architect and owner to interpret reasonable responses to these studies. Therefore, we respectfully ask you to oppose a building code amendment regulating reflectivity and to encourage the continued use of area-specific zoning regulations to address this issue on a case-by-case basis. We look forward to meeting with you after the holidays, and we appreciate your thoughtful consideration on this matter. Sincerely, The Building Industry Coalition AIA Dallas Downtown Dallas, Inc. NAIOP North Texas The Real Estate Council TEXO, The Construction Association Uptown Dallas, Inc.