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Codes and Standards Update 2018 Q2

Created 8/20/2018 by Bing Liu
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Codes Update

National/Regional Level

    • NEEA staff and its contractors contributed to the planning of DOE’s National Energy Codes Conference by identifying the session topics, lining up the speakers and chairing three technical sessions. The topics focus on the codes education, training, and implementations. DOE’s codes conference will be held on July 15-18, 2018 in Austin Texas.
    • NEEA and its contractor developed a white paper on the Whole Building Energy Efficiency Program Incentives. As a follow up, NEEA and its contractors plan to convene a regionally representative group to begin a discussion on whole building incentive programs. The expected outcome is a regional roadmap that will assist in utility and regional decision making on whole building programs. This anticipates a future where measure by measure savings become more difficult to document.
    • Contractors continued to develop a white paper to look at decision points connected with establishing a common regional baseline for measuring code and other program savings.


State Level


    • The 2018 Washington Commercial Energy Code development is underway. NEEA and its contractors submitted 42 proposals (19 of these proposals were most clean up). A total of 171 proposals were submitted. WA Building Energy Codes Technical Advisory Group will conduct a series of public meetings to review the proposals in Q2 and Q3. Below is the list of proposals from us that will have reasonable energy savings:
  1. Lower lighting power density (LPD) allowance tables than current values are being proposed and offer the most potential savings in the Washington Energy Code.
  2. Performance Path Modeling based upon Appendix G proposal to replace current modeling path. This proposal uses fixed baseline with higher performance targets reflective of better practice buildings to achieve savings.
  3. HVAC Total System Performance Ratio proposal. This proposal extends modeling to smaller buildings and limits the selection of poor HVAC systems in buildings to drive savings.
  4. NEEA has contracted with NBI to develop proposals associated mainly with Multifamily projects but also includes other type buildings. The proposal includes:
      • U value glazing requirements that decouple frame type for u-value and increase u-value requirements.
      • Fan efficacy requirements for smaller exhaust fan based upon energy star requirements
      • Higher lighting efficacy requirements for “high efficacy lighting” definition to update the state of current technology.
  5. Air barrier testing will be required to past air leakage testing without exception. Many buildings outside of Seattle are not tested as there is not a technical requirement that the buildings actual pass a test. This proposal will remove the option of not passing.
  6. NBI has developed a proposal based upon PNNL original concept to achieve a point system in the additional efficiency packages that will likely drive additional efficiency packages choice based upon building type and realistic savings. This proposal will encourage parity in the additional efficiency package selection that achieve a given level of savings as opposed to being based strictly based upon cost to implement. This drive to parity will likely result in more saving in the additional efficiency packages in the range of .5 to 1% whole building savings.
    • Two code proposals for the 2018 Washington Commercial Energy Code provide additional code compliance paths not only offer savings but also allow flexible design options, including

1) a new performance path using ASHRAE 90.1 Appendix G with fixed-baseline modeling ruleset, and

2) an HVAC system equalizer approach that will provide efficiency correction factors based on system selection.

  • Code & Standard staff worked with NEEA’s gas team on two code proposals for the 2018 Washington Commercial Energy Code. These proposals included:
    1. Optimum stop proposal that requires commercial building implement optimum stop in the sequence of operation. This modification to the sequence of operation will allow building cooling and heating set points to float up to 2˚F the last 30 minutes of the day. This will prevent unnecessary heating or cooling just prior to the building becoming unoccupied at the end of the day and results in savings.
    2. Efficient Kitchen Additional Efficiency package. This proposal adds additional efficiency package for building types that use fryers or ovens. Energy star fryers and ovens are required to receive this as one of the additional efficiency packages. This achieve gas and electric savings and allows contractors more flexibility in their choice to meet code requirements.


    • The 2017 Oregon Residential Specialty Code (residential energy code) goes into effect on January 1, 2018. NEEA’s contractor conducted an analysis to estimate the energy savings and cost effectiveness over the previous code (2014 edition). The analysis shows that the overall site energy saving from the 2017 edition is 6.1% by comparing to the 2014 edition, including single family homes and low-rise multifamily buildings across the state of Oregon.    
    • The 2019 Oregon Structural Specialty Code (commercial energy code) development is underway. The 2019 OSSC Code Review Committee conducted a series of all-day meetings in May and June to review the public code proposals. After the final public codes meeting, the committee will make a recommendation to the Building Codes Structures Board. The Board then will review the committee’s findings and make a final recommendation to the Building Code Division for adoption.
    • There were 31 proposals submitted, including 12 proposals submitted by NEEA and the Oregon Code Collaborative. Among 12 submitted proposals, 8 proposals were advanced to the next stage or expect to be advanced at the June 12 meeting. Below is the list of proposals from us that passed through the Committee and will have reasonable energy savings:
  1. Receptacle load control for 50% of open office, removed copy and print room provisions.
  2. Two additional efficiency packages in addition to base code required instead of one.
  3. DOAS requirements enhanced with essential best practices for the Additional Efficiency Package.
  4. Optimum stop on boilers.
  5. Efficient Kitchen equipment.
  6. Indoor Ag – Specifies exception to having economizers in lieu of adding equipment that is 20% more efficient than federal standards, and specifies minimum performance requirements for standalone dehumidifiers.
  7. Parking ventilation controls – Reduces exception threshold for installing parking garage ventilation controls from 25,000 sf down to 8,000 sf.



  • Idaho Energy Code Collaborative is planning to host a one-day energy code conference in Q4. The conference plans will focus on the energy code training geared to code officials, designers and builders. The conference will be organized by the Idaho Association of Building Officials.



  • The Building Codes Bureau has prepared adoption recommendations for all codes but the energy code. The adoption process is stalled because the Governor has not established the current membership of the Building Codes Advisory Council. Listening sessions for the energy code have not yet been scheduled.
  • NEEA’s contractor developed two issues of Energy Codes Best Practices newsletters this year. The primary topic was roof insulation with an emphasis on the unvented assemblies. The digital newsletter was distributed to building departments, the MT DEQ, and the local home builder associations. These entities are in turn asked to distribute the newsletter through their email contact lists.

Standards Update


Federal Level

As in the first quarter, there was very little action of note at US DOE. There is still no resolution of the lawsuits filed against DOE by thirteen states (including New York and California) and efficiency and consumer advocacy organizations for its failure to publish in the Federal Register four Final Rules that entered the 45-day “error correction” period just prior to the change in administrations. DOE was ordered by the Ninth Circuit Court in California to publish the rules within 28 days. They also had the right to appeal. On June 25th DOE filed a brief with the Ninth Circuit claiming the court had improperly circumscribed their authorities by mandating publication. So the Court will have to weigh in once more before this set of issues will be resolved.

The only other significant activities at the federal level this quarter have been a flurry of test procedure waivers for HVAC and refrigeration equipment, and the very beginning of a test procedure rulemaking for VRF-type systems. In general, the waivers are being granted, but often with caveats with regard to alternative test and rating procedures. See the details below on the VRF test procedure proceedings.

VRF System Test Procedure Rulemaking. DOE Issued a Notice of Intent to Establish a Working Group for Variable Refrigerant Flow Multi-Split Air Conditioners and Heat Pumps on April 5th, 2018. NEEA applied as a member for the working group in April. Nominations to the committee were announced 7/2/2018. NEEA along with Tom Eckman (NWPCC), Marshal Hunt (P G&E), Kristin Driskell (CEC) were approved for the working group with the first meeting occurring August 23 and 24th. The working group will negotiate test procedures and standard levels for VRF equipment. The test procedure for this equipment presents many issues in reflecting actual field energy use. Some of the issues include that the equipment is typically tested with two cassettes or heads however most equipment used in commercial applications in the field has many cassettes ( 8 or more). The testing burden associated with testing multiple heads is substantial and likely results in lower efficiency and more energy use with the more heads that are tested. Other issues associated with testing vs actual energy use include equipment mode settings and initial set up by installing contractor. Understanding typical and representative settings for VRF equipment that represent likely field energy use will be difficult to assess. NEEA and PG&E have data that may shed light on a number of issues between field energy use and actual energy use however solutions are likely to remain elusive.

 State Level


As noted in last quarter’s report, the California Energy Commission’s (CEC’s) 2018 agenda was set up to consider standards for a number of different products or categories that are not yet regulated at the federal level. The ones for which an RFI has been issued so far include:

  • Hearth Products
  • Commercial and Industrial Fans and Blowers
  • General Service Lamps (Expanded Scope)
  • Spray Sprinkler Bodies
  • Irrigation Controllers
  • Commercial and Industrial Air Compressors

Ones that will have a lower priority and be addressed later are:

  • Tub-Spout Diverters
  • Set-Top Boxes
  • Low-Power Modes and Power Factor
  • Solar Inverters

NEEA submitted data and comments in response to the CEC’s RFI for high-CRI fluorescent lamps (typically 4-foot and 8-foot T8 and T12 lamps with a CRI greater than 87). The next step will be a Commission decision on beginning a rulemaking to establish standards for them. If the CEC establishes standards, it’s likely that other states will also adopt the standards. Vermont has already passed standards for these lamps (see below).


CEC published regulations on Fans and Blowers that will be considered as possible amendments to the Appliance Efficiency Regulations (Title 20, California Code of Regulations, Section 1601 through 1609). An RFI was issued last year indicated intent to regulate fans and blowers. The CEC also announced that a workshop will be held on July 11, 2018 in Sacramento. NEEA will be attending this meeting. Fan regulations are contentious due to the inclusion of regulating fans embedded in air conditioning equipment. NEEA and advocates favor this approach as many of these fans are not regulated by another energy efficiency metric and this present the opportunity to achieve savings unlikely to be obtained otherwise.


In May, the Vermont legislature passed a bill that set or updated standards for sixteen products including air compressors, commercial dishwashers, commercial fryers, commercial hot-food holding cabinets, commercial steam cookers, computers and computer monitors, faucets, high color rendering index fluorescent lamps, portable air conditioners, portable electric spas, residential ventilating fans, showerheads, spray sprinkler bodies, uninterruptible power supplies, urinals, and water coolers. On May 21st, Governor Scott signed the bill. Vermont thus became the first state to establish standards for air compressors, high CRI lamps, portable air conditioners, residential ventilating fans, and spray sprinkler bodies. The air compressor and portable air conditioner standards are subjects in the Ninth Circuit law suit mentioned above, and if DOE is forced to publish its standards, those products will be pre-empted in the states. Vermont’s action makes it more likely that other states will follow suit. There are similar bills in the legislature in Massachusetts and Rhode Island yet to be decided upon, and the CEC in California is working on a few of these products, as noted above.


In Oregon, the Oregon Department of Energy (ODOE) began public meetings late in the quarter to consider a legislative concept that would give ODOE somewhat more initiative and authority in the processes for setting efficiency standards for the state. Today, the legislature has to set new standards, while ODOE can administratively update existing standards, followed by a bill being introduced for legislative review in the subsequent session. That process will conclude this summer. If the new procedures in the legislative concept aren’t submitted to the legislature for the next session, ODOE will have to use its existing authorities to move state standards forward.

Other Non-federal News

NEEA, as part of Canadian Standards Association (CSA) Task Group, has submitted new test and rating procedures for heat pump and air conditioning systems to CSA for final editing and promulgation (expected in the third quarter). The resulting standard will be a stable technical draft to be used by test laboratories (including manufacturer labs) to test and rate a number of “systems of interest” to programs. Over the next year, a consortium of interested parties, including NRCan, NEEA, NEEP, CA utilities, and others, will test and rate approximately 30 systems while gathering technical feedback on the test procedures themselves. After receiving feedback from labs through mid-2019, CSA intends to upgrade the standard and publish it as a voluntary Annex to C656 (the Canadian equivalent to DOE’s Part 430, Appendix M test procedures for these products). Program operators and others can use the standard and its resulting ratings to much more reliably identify which systems perform best in which climate zones. The standard provides seasonal COP ratings for heating and cooling in 8 climate zones, including sub-Arctic.

Work has now begun on new test and rating procedures for split system air-to-water heat pumps used for the domestic hot water end use.


NEEA is also working on a commercial CSA gas test procedure P.8 for regulating modulating commercial gas furnaces. NEEA and our contractors our working on a furnace test procedure that would show potential benefit of modulating gas furnaces whether that is two stage, continuous modulating or condensing gas furnaces greater than 225,000 Btu/hr. We have been working on the test procedure with other members of CSA P.8 committee since January and expect to have a rough draft of the test procedure completed at the end of September.


Please contact Bing Liu (BLiu@neea.org) if you have questions about the Codes and Standards Program.


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