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Codes and Standards 2018 Q3 Quarterly Update

Created 10/26/2018 by Bing Liu
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Codes Update

National/Regional Level

    • NEEA presented a paper “Market Transformation Strategies for Commercial Code Enhancement” at the ACEEE Summer Study on August 15. The paper explains the concept of CCE and how NEEA is working with the market, Code, and utilities to create greater alignment and understanding of upcoming codes in the Northwest. The paper can be found on Conduit or in the ACEEE Summer Study proceedings.
    • NEEA and its contractors continues to work on the code change proposals to 2021 IECC. NEEA plans to submit several proposals by January 2019 deadline.

State Level


    • The 2018 Washington Commercial Energy Code development is progressing this quarter. Washington Building Energy Codes Technical Advisory Group (TAG) held eight all-day meeting in June, July and August and completed the reviews of all 171 proposals submitted. NEEA and its contractors attended and participated in these meetings. Below is the list of proposals from NEEA that will have reasonable energy savings or impactful in progressing to Washington States long term legislative energy code goals:
  1. Lower lighting power density (LPD) allowance tables were passed in the TAG. This proposal offers the most potential savings in the Washington Commercial Energy Code. The proposed values are 4.5% lower than current values and were based on ASHRAE Standard 90.1-2016 values.
  2. Performance Path Modeling based upon 90.1-2016 Appendix G was passed in the TAG. This proposal uses fixed baseline with higher performance targets, reflecting better building design and construction practices to achieve savings.
  3. HVAC Total System Performance Ratio proposal was passed in the TAG. This proposal establishes a new energy metric to measure the whole HVAC system efficiency. It limits the selection of poor HVAC systems in buildings to drive savings.
  4. Air leakage testing was passed in the TAG. This proposal removes the options for not conducting air leakage testing.
  5. Optimum stop proposal was passed in the TAG. This proposal requires commercial building implement optimum stop in the sequence of operation, which allows 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.
  6. Efficient Kitchen Additional Efficiency package was passed in the TAG. This proposal adds an additional choice of efficiency packages for certain building types that use fryers or ovens. The efficient kitchen package requires Energy star fryers and ovens be installed 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.
    • Commercial Code Enhancement (CCE) met with Washington Utilities in July to present a University of Washington Integrated Design Lab scanning report that identified measures that could be considered in future Washington code cycles. CCE will re-engage with Washington Utilities and key code stakeholders in Q4 to kick off a long-term code road mapping process that will continue into 2019.


    • The 2019 Oregon Structural Specialty Code (commercial energy code) development was underway. The 2019 OSSC Code Review Committee conducted a series of all-day meetings in May and June to review the public code proposals. Three of these meetings were specifically to discuss energy code proposals. After the final public codes committee meeting, the Review Committee recommended proposals that will be provided to the Building Codes Structures Board during the Board’s upcoming November 7 meeting. The Board then will review the committee’s findings at this same public board meeting and make a final recommendation to the Building Code Division for adoption. BCD will then review the board’s recommendations and conduct rulemaking (likely in early 2019) to formalize the adoption of the new code and prepare code materials for an effective date of October 1, 2019.
    • Commercial Code Enhancement met with the Energy Trust of Oregon in August to review the University of Oregon scanning report and lighting data from the Energy Trust New Buildings program. The lighting data will provide an idea of how commercial new construction buildings achieve above code targets and could be used to inform future code proposals. CCE will continue exploring data needs and analysis with the Energy Trust in effort to align future code requirements with market best practice.



  • Idaho Energy Code Collaborative finalized the conference agenda and speakers for a one-day energy code conference that will be held in Boise on October 2. The conference will focus on the energy code training geared to code officials, designers and builders. The conference was organized by the Idaho Association of Building Officials.
  • Commercial Code Enhancement met with Idaho Power, Office of Energy and Mineral Resources (OEMR), and the University of Idaho Integrated Design Lab (IDL) to go over IDL scanning report of potential future code measures. CCE will continue working with Idaho Power to explore how CCE can support Idaho Power commercial program development in response to upcoming code changes.
  • NEEA and its contractor completed the data collection for the Idaho Residential Code Field Study. PNNL and NEEA have completed the data reviews and Idaho Residential Energy Code reviews. PNNL is in process to conduct the data analysis. Draft report will be sent to the Idaho Energy Code Collaborative for review in Q4.



  • In lieu of in-person trainings NCAT is developing online educational material about the current Montana residential energy code. The online information would be organized into about 20 topics. This online material would be offered online by local homebuilder associations, the State Building Codes Bureau, the State Department of Environmental Quality, and local building code departments. These entities will have the option of either adding the material to their web sites or simply linking to a central web site. This material will be placed online during the fourth quarter of 2018. The material will be updated when the state adopts the 2018 IECC.
  • The status of the energy code update process has not changed during September. The adoption process remains stalled because the Governor has not established the current membership of the Building Codes Advisory Council. The Building Codes Bureau plans to wait until the non-energy codes are adopted before holding listening sessions for the energy code. The best guess is that the 2018 non-energy codes will be adopted by mid-2019 with the energy code adopted by the end of 2019. Among other things, this delay impacts NEEA and Northwestern Energy plans to provide education targeting the updated energy code.
  • Commercial Code Enhancement meeting is scheduled for October 25. Agenda items will include: 1) reviewing Montana State Integrated Design Lab’s scanning report; 2) finalizing the Montana State Coordination Plan (SCP), and 3) discussing data exchanges between CCE and Montana utilities.


Standards Update


Federal Level

DOE has issued several test procedure waivers for HVAC and refrigeration equipment this quarter. In general, the waivers are being granted, but often with caveats regarding alternative test and rating procedures. See the details below on the VRF test procedure proceedings.

DOE published a Notice of Joint Stakeholder Proposal for a Direct Final Rule for Energy Conservation Standards for Dedicated-Purpose Pool Pumps Motors. This rulemaking has very limited energy use impact in the Pacific Northwest region. There is currently no information available on when or if such a Direct Final Rule will be published. DOE also published a Final Rule for the Test Procedures for Integrated Light-Emitting Diode Lamps.

DOE issued a pre-publication Request for Information with regard to the test and rating procedures for 3-phase air conditioning and heat pump systems of 65 kBtu/hr capacity and smaller. The text of the RFI strongly suggested that the intent in this potential rulemaking is to simply align the 3-phase procedures with the single-phase procedures published in the summer of 2015, which become effective on January 1st, 2023, with new standards.

There was no progress 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 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. The Court will have to weigh in once more before this set of issues will be resolved.

VRF System Test Procedure Rulemaking. Following up on its Notice of Intent to Establish a Working Group for Variable Refrigerant Flow (VRF) Multi-Split Air Conditioners and Heat Pumps in the second quarter, DOE established the ASRAC working group in August, publishing a meeting schedule on September 5th. NEEA is a member of the VRF Working Group.  The first meeting of the working group occurred August 23rd and 24th.  The working group has scheduled 10 meetings to negotiate test procedures and standard levels for VRF equipment. The test procedure for this equipment appears to do a poor job of predicting actual field energy performance. PG&E completed lab testing in the 3rd quarter and the results indicate that the current test procedure yields inaccurate ratings. Field energy use of a Davis site was compared to the rating results of an alternate to the AHRI 1230 test and rating procedures and the results were very similar.  The 1230 test yields very inaccurate efficiency ratings at part loads that were half as efficient as the rating would indicate. DOE has indicated they have found the 1230 test representative of field use although the forward test section of the 1230 document indicates that the test procedure should not be used to predict the energy use of equipment. The requirement that the efficiency rating be representative field energy use is in federal statute. This inaccuracy of this test procedure is typical of many test procedures.

State Level


As noted in earlier quarterly reports, the California Energy Commission’s (CEC’s) 2018 agenda was set up to consider standards for several 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). NEEA also submitted comments on September 28th in response to the CEC’s Commercial and Industrial Fans and Blowers pre-rulemaking document. NEEA suggested regulating embedded fans in equipment as in our original comments and provided a specific approach in our comments.


The rulemakings for Hearth Products, Commercial and Industrial Fans and Blowers, Commercial and Industrial Air Compressors, and General Service Lamps officially began this quarter. Initial industry comments in all four of these rulemakings suggest that all will be somewhat controversial, even though CEC will follow closely the published and unpublished DOE rules for the same products. Should DOE publish Final Rules for these products (except for Hearth Products, a rule for which has not yet been contemplated by DOE), the CEC will defer to the federal rules, except where federal coverage is lacking. More on these important rulemakings as they unfold. The energy savings from most of these are potentially large.



The Oregon Department of Energy (ODOE) concluded its process to consider a legislative concept that would give ODOE more initiative and authority in the processes for setting equipment efficiency standards for the state. In the face of consistent industry opposition, ODOE decided not to pursue new legislation, opting instead to stick with their current authorities where ODOE can administratively update existing standards or propose new standards, followed by a bill being introduced for legislative review in the subsequent legislative session. It remains to be seen if ODOE will use their existing authorities, which have existed for many years now, unused.


Other Non-Federal Level

The Canadian Standards Association (CSA) Task Group working on new test and rating procedures for heat pump and air conditioning systems. The Task Group completed final editing on new test procedures this quarter. Publication is expected before the end of October. The resulting standard will be a stable technical draft to be used by test laboratories (including manufacturer labs) to test and rate several “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, as needed, 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.

NEEA and CSA continues 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 for regulating modulating commercial gas furnaces. NEEA and our contractors are 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 will have a final test procedure completed at the end of October ready for public review period.


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



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