Energy code changes lead to interesting relationships, full of histrionics, hyperbole, and drama. Lots and lots of drama. Particularly around proposed change RE166.
Lobbyists of all sorts come out to play, some misleading (Trust me, the name of my group has “Save” or “Energy Efficient” in it!), all interested in advocating whatever position they are paid to. The last time I saw this much drama and duplicity, I was watching the Scottish play by Shakespeare.
I’ve been looking at some of these proposed changes and the players involved and came to the realization that there are a lot of bad actors out there- not like community theatre performances of the Scottish play, but like watching that play unfold in real life. It seems as though malevolent forces are at work to usurp reason and logic through exaggerated claims that support their pre-determined position.
I guess what really cheeses me off about this is the way these actors behave: demonizing the opposition (sort of like what I’m doing right now), using scare tactics and, worst of all- rejecting reason and consistency of thought.
Proposed energy code change RE166, for example, proposes to allow mechanical equipment efficiencies to be used to meet the performance-based approach to energy code compliance. This approach is based on the Proposed Home meeting the annual energy use cost budget established by the prescriptive path-based Reference Home.
I was asked to research the impact of RE166 on the performance-based approach to energy code compliance. I was paid to do the research, but the client asked me to determine what the impact would be- not make my research results fit their ideas.
Since I prefer evidence over emotion (stems from my work as a surveillance operative), I took this approach to finding the answer:
1 What is the question? For me, it was “Does allowing mechanical equipment efficiencies to meet the prescriptive annual energy use cost budget of the 2012 energy code have an impact on energy costs related to heating, cooling, and domestic water heating?” The follow-up question was “If so, what is the impact?”
2 What other work has been done on this? I found two valuable pieces of work. One document, produced by the Florida Solar Energy Center and authored by Philip Fairey, established a methodology for analyzing energy code compliance relative to a HERS Index, and the other document, produced by Pacific Northwest National Laboratory in 2012, established the methodology used by the Department of Energy to make a determination of the cost-effectiveness of residential energy code changes.
3 Experiment. Thanks to the methodologies uncovered in my preparative work, I was able to devise an experiment to simulate the impact of mechanical equipment efficiencies on energy costs for heating, cooling, and domestic water heating and determine the comparative impact to a home built to the 2012 energy code prescriptive path. The only variation between the control (2012 energy code Reference Home) and the experiment (Proposed Home) was the mechanical equipment efficiency and capacity. I performed the experiment simulation in 19 cities, spread across all 8 climate zones, and used 3 foundation types, 2 heating types, and 2 water heating types. I first ran the experiment and compared the current prevailing federal minimum efficiency standards (2012 energy code) with the federal minimum efficiency standards for mechanical equipment that go into effect in 2015. My second set of experiments compared the 2015 federal minimum efficiency standards to slightly more energy efficient mechanical equipment that is “state-of-the-shelf”.
4 Observation. In every single case, the use of mechanical equipment efficiency to meet the annual energy use cost budget of the 2012 energy code Reference Home resulted in a home that was more energy efficient on a cost-basis.
5 Review. After documenting my observations, I circulated them to a select group of colleagues who have demonstrated a willingness to challenge my ideas. This produced clarity in the final report.
The entire time I kept hearing my colleague from DOW, Dan Tempas, saying “It’s more important that the right answer is my answer, than my answer is the right answer.” The concept is to base your findings on evidence, not evidence upon your findings.
One of my observations that I found interesting: apparently, you can get away with murder in Miami, but get the death penalty for jay walking in Fargo. Homes built to the minimum prescriptive code standards zipped past the performance-based thresholds in Miami, but homes built to the minimum prescriptive code standards barely met the performance-based thresholds in Fargo.
I examined the arguments against RE166. It was difficult because most of the arguments are misleading and based on a fallacious understanding of how the performance-based approach to energy code compliance works.
They have laid outrageous claims of rolling efficiency levels back to pre-2009 energy code levels (not true) and that RE166 will cost consumers thousands of dollars because mechanical equipment efficiencies are not cost effective (also not true).
1 The Department of Energy (with the support of groups now opposed to RE166) has already made the determination that using improved mechanical equipment efficiencies is cost-effective for the consumer, and has adjusted the prevailing federal minimum efficiency standards accordingly with an effective date of January 2015 for heating and cooling equipment and April 2015 for water heating equipment.
2 The 2012 commercial energy code allows the use of improved mechanical equipment efficiencies to meet the annual energy use cost budget by using the prevailing federal minimum efficiency standards as the baseline in the Reference Building, while the 2012 residential energy code does not allow it by using the efficiency of the mechanical equipment in the Proposed Home as the baseline in the Reference Home.
3 The methodology used by the Department of Energy to determine the cost-effectiveness of proposed residential energy code changes includes using the prevailing federal minimum efficiency standards for mechanical equipment as the baseline in the Reference Home, exactly as proposed by RE166.
RE166 homes will inherently be more energy efficient than a prescriptive home built to the current 2012 energy code because the prevailing federal minimum efficiency standards increase in 2015.
These same actors who are now opposed to RE166 pushed for those federal minimum efficiency standards to go up because they are cost-effective for consumers! And now they are claiming they aren’t?
Since the Proposed Home has to meet the annual energy use cost budget set by the prescriptive-based Reference Home, it is IMPOSSIBLE for the Proposed Home to be less efficient (in terms of energy cost to the consumer- the metric used in the performance-based approach) than a home built to comply with the prescriptive approach to energy code compliance.
The fear-mongering and emotional intimidation tactics used by opponents of RE166 are disturbing. Their arguments indicate inconsistency in thinking, a gross misunderstanding of how the performance-based (house as a system) approach to energy code compliance works, and a denial of reason.
Unfortunately, many well-intentioned groups have fallen for these misleading claims. Probably as a result of these actors having “Save” or “Energy Efficient” in the names of their organizations- we tend to naively assume that the name reflects the character. And, like the king in the Scottish play, we are deceived.
Apparently these actors also forgot the purpose statement of the 2012 residential energy code:
“R101.3 Intent.
This code shall regulate the design and construction of buildings for the effective use and conservation of energy over the useful life of each building. This code is intended to provide flexibility to permit the use of innovative approaches and techniques to achieve this objective.” (http://publicecodes.cyberregs.com/icod/iecc/2012/icod_iecc_2012_re1_sec002.htm?bu=IC-P-2012-000014&bu2=IC-P-2012-000019, retrieved September 21, 2013)
I guess they only want flexibility and innovation allowed if it fits their biased, pre-determined views.
I strongly encourage rational human beings to support RE166 and other proposed energy code changes that provide flexibility and innovation while meeting the annual energy use cost budget (so the homes will not be less efficient). And if you’re not rational, I suggest taking a deep look at…never mind, irrational people are by definition incapable of critical thinking.
Just check out the source of the information you base your decisions on, evaluate them, and use good judgment to make up your own mind.
The Building Envelope
The building envelope is an air barrier and thermal boundary that are continuous and touching and separate conditioned space from unconditioned space or the outside. The envelope of a simple house may be the floor, the walls (including exterior doors and windows) and the flat ceiling. There are many ways for a builder to define the building envelope (it can contain a conditioned basement, a sealed, insulated and conditioned crawlspace, a conditioned attic with insulation along the roofline) and even more ways for them to fail to define it properly.
I have seen homes where the builder conditioned part of the attic without insulating the roofline or gable wall and there was a case where a code official (in ignorance) required a builder to condition the garage with a duct from the house in order to keep the water pipes from freezing. The garage IS NEVER INSIDE THE BUILDING ENVELOPE! If there is a desire to provide conditioning to the garage, it must be conditioned by a separate system than the house.
The builder gets to define the building envelope by deciding where to place the insulation and air barriers.
The building envelope’s function is to protect the occupants of the home from the elements (air, heat, cold, water).
One myth about the building envelope is that all we need to do to improve it is to add more insulation. A certain utility program recommended increasing the amount of attic insulation to R-49 to decrease the amount of heat loss and gain through the ceiling; at the same time, they recommended that extensive airsealing shouldn’t be done because “houses need to breathe” and airsealing would increase the amount of pollutants in the home.
This is another myth: airsealing the home prevents pollution from entering the home from the basement, crawlspace, carport, attached garage, attic and outside.
By the way, houses don’t need to breathe, but people do- so add intentional ventilation for the people!
Online Job Training
Online job training has become the buzzwords for a lot of folks over the past couple of years. In 2010, I wrote myself the following note:
“Since close to a third of all job training is delivered electronically, I’ve been exploring some of the advantages and pitfalls of this knowledge delivery system. I must admit that I am not a big fan of electronic learning, particularly online
courses, primarily because of my experience with the courses I’ve participated in.
I attended one asynchronous (accessible to me at any time or place) NAHB course where the “instructor” essentially read word for word the massive amount of text that was presented on my computer screen- and I couldn’t advance to the next screen until they finished the narration! Since I read around 1,000 words per minute, you can imagine my frustration- I think by the end, I would have rather lain through a colonoscopy!
I participated in a synchronous, collaborative (instructor-led, available only at a single time, interactive) online course that was essentially presentation slides that the “instructor” led us through. Forget the fact that these slides had way too much text that the instructor read and graphics that didn’t connect with the text, we also suffered from other attendees who were engaged in side bar conversations with random people who strolled into their offices, we were entertained by barking dogs, trains whistles and one person who took their phone with them into the bathroom while they umm… proceeded to pee in what I presumed was the toilet!
As I look at these different delivery mechanisms, there are several things that I’ve become aware of: first, the rush to online learning is probably premature for most of the organizations currently delivering services; second, most of the designers of online learning media are clueless about how to design curriculum for web-based learning; third, most users of online learning get frustrated multiple times by poor instructional design, lousy content and poor presentation skills.
But don’t we all need to embrace this technology and advance into the future? I’m certain we should, but we should first look at the principles behind online learning and create engaging, meaningful, solution-oriented curriculum that addresses the workforce needs and design for the delivery system.
I have people ask me all the time if I’m going to offer my HERS Rater course online. I will at some point, but I want it done right the first time. So while I was sitting at a Whataburger restaurant, eating breakfast with my 17 year old son one Saturday morning, it occurred to me that these folks who were asking for online training were not really asking for it. What they were really asking for is convenience, low course cost, the ability to train at their own pace, and no travel costs. I tend to not listen to what the customer is “asking for”, but instead listen to their verbalized requests to find out what they are really asking for. What is it they really need and want?”
Since I first wrote that note in September 2010, I’ve thought of ways to deliver what they are really asking for- and now I think I’ve found the solution. We are now delivering online job training using curriculum designed for the web, which provides a rich, learn at your own pace format.
Green Job Training: Tasks or Thinking?
Green job training programs often focus on teaching students how to do certain tasks related to sustainability. The goal is to fill the student’s mind with facts and memorized behavior- and after passing a standardized test, we have a certified worker capable of being deployed in the workforce. Really?
Socrates saw the process of education as drawing out instead of filling up the mind. In an essay on education written in 1673, Obadiah Walker laid out the notion that learning isn’t about memory but the ability to understand, discern, and solve problems.
In the late 1800’s, William James developed a theory that education is “the organization of acquired habits of conduct and tendencies to behavior.” He believed that the key to retaining knowledge was to form diverse and multiple associations around facts by thinking about them, discovering their hidden similarities and distinctions, and their “causal sequences”. He opposed simple verbal recitation, preferring varied statements and practically testing the student’s conceptions.
It is amazing to me that we see an industrialized approach (training to the lowest common need) taken when dealing with green job training- or frankly, any kind of vocational training. The idea that a tradesman or craftsman need only be concerned with completing sequenced tasks without regard to the work of others, or the impact of the quality of their work on the final product, is ridiculous.
This is especially true when dealing with green job training. Sustainability is effectively using our resources today to meet our needs, while preserving resources for future generations.
Simply teaching someone how to robotically perform tasks related to sustainability without teaching them how their work fits into a bigger picture, or how to think about their work so they can perform it in the most efficient way, minimizing wasted resources while meeting the goals of their work is unconscionable.
Yet that is precisely what we do with most of our so-called “green job” training.
We teach them how to push caulk into a hole, which type of caulk to use for different holes, how to install insulation correctly and where it goes, how to install and seal ductwork, how to test for leaky ducts and leaky homes, even how to describe a home using software- but rarely do we teach them how to think about WHAT they are doing and WHY they are doing it.
How can we label a process as “green job training” when what we are teaching is inherently unsustainable?
The airsealing guy is taught to put sealant in specific holes or places- but what happens when the plumber puts a hole in a different place? Or the framing detail of some angled walls creates a new hole open to the attic? Now they have to make another trip, wasting time, fuel, and employer’s money.
What about the duct tester who realizes it is more efficient time-wise to place a large piece of duct board with a hole in it over the return box at rough-in testing- so they don’t waste tape- but the hole in the duct board is smaller than the diameter of the flexible air connector connected to the duct testing fan? The fan pressure is going to be higher, which will make the duct leakage test results different…possibly affecting the outcome of the HERS Index! When this poor practice gets discovered, the duct system will have to be re-tested, again wasting time and money- all because they weren’t thinking about their job.
Green job training should be more than teaching tasks- it should teach the student HOW to think about those tasks.
John Stuart Mill wrote in 1867: “Education makes a man a more intelligent shoemaker, but not by teaching him how to make shoes: it does so by the mental exercise it gives.”
Shouldn’t green job training do the same?
ENERGY STAR HVAC Design
ENERGY STAR HVAC design is not hard, really…all that needs to be done is a proper Manual J, select equipment using Manual S, and design the duct system according to Manual D. Yet…we are constantly finding “a failure to communicate” between Raters and HVAC Contractors.
ENERGY STAR HVAC design is simply following the ANSI Standard for Quality Installations of HVAC, ACCA’s Standard 5. I imagine the EPA is discovering that many Raters are passing HVAC checklist items that should not have made it through. Advanced Energy has reported numerous cases where the Rater has simply checked off boxes- instead of actually using the checklist as a guide for doing the work.
One of the challenges in the ENERGY STAR HVAC design process is when the documentation for the HVAC design is handed off to the Rater. Typically, that happens at the end of the game AFTER the equipment is installed and commissioned. Then, it is too late to do anything about improperly selected equipment based on improper HVAC design. However, the Rater is NOT required to verify that Manuals S & D were done…yet. I’ve recently highlighted that issue to the EPA and they are in the process of re-writing the guidelines for HVAC Quality Installation oversight organizations.
Simple checks to see if a Manual S & D were performed, requirements of an ENERGY STAR HVAC design process:
1 Check the HVAC Contractor-recorded capacities at design conditions. Does the total capacity magically match the total capacity on the AHRI certificate? If the answer is yes, they didn’t do a Manual S- which would require them to use the interpolated capacities at design conditions from the OEM expanded product performance data. Since the AHRI tests are done at specific conditions (80 degrees inside, 95 degrees outside- with a 67 degree indoor wet bulb), unless the house in question is at those conditions- the capacities will be different. Some manufacturers like Carrier even provide a web-based interface that calculates the capacities at design conditions…so it really isn’t hard. Oh- it’s also required by the 2009 IRC.
2 Check the duct design static pressure. Compare it to the HVAC Contractor-measured External Static Pressure. Is the measured ESP within 25% or 0.10 i.w.c. of the duct design static pressure? If not, it does NOT meet the ANSI Standard for Quality HVAC Installations (required by the EPA for HVAC contractors)…and a clear indication a Manual D was not performed….and Manual D is also required by code (or an equivalent).
I can foresee Raters getting asked to perform these types of HVAC design checks in a future revision of ENERGY STAR- especially since many of the homes that have HVAC designed under the current “we’ve always done it this way” method are ending up with comfort complaints…which get blamed on ENERGY STAR for requiring the HVAC contractor to use the 1% and 99% outdoor design values for the closest location to the home.
And that, my friends, is a real crock of…well, we all recognize it for what it is. Blaming the outdoor design values when the rest of Manual J is ignored, no Manual S procedures followed to match the equipment with the load profile, and ignoring good duct design and installation to deliver what was promised- that is simply childish.
It is really disheartening to hear that some HVAC contractors (who know better) are taking that exact approach to cover their ass with the builder and drive the builder away from high performance homes using comfort fears (which are realized when you DON’T follow the quality HVAC design process).
But it underscores something even more disturbing- the integrity of a trade contractor who signed an agreement with an oversight organizations stating they would comply, then signed an agreement with the EPA agreeing to abide by the rules, then signed a contract with a builder that promised to deliver ENERGY STAR quality HVAC design and installations- and then the contractor COMPLETELY IGNORED every single commitment they made and continued with business as usual. My dad would have fired them on the spot.
In the construction industry, it isn’t about what you promise- it’s what you deliver that counts.
Murder in Miami: RE166 Proposed Energy Code Change
Energy code changes lead to interesting relationships, full of histrionics, hyperbole, and drama. Lots and lots of drama. Particularly around proposed change RE166.
Lobbyists of all sorts come out to play, some misleading (Trust me, the name of my group has “Save” or “Energy Efficient” in it!), all interested in advocating whatever position they are paid to. The last time I saw this much drama and duplicity, I was watching the Scottish play by Shakespeare.
I’ve been looking at some of these proposed changes and the players involved and came to the realization that there are a lot of bad actors out there- not like community theatre performances of the Scottish play, but like watching that play unfold in real life. It seems as though malevolent forces are at work to usurp reason and logic through exaggerated claims that support their pre-determined position.
I guess what really cheeses me off about this is the way these actors behave: demonizing the opposition (sort of like what I’m doing right now), using scare tactics and, worst of all- rejecting reason and consistency of thought.
Proposed energy code change RE166, for example, proposes to allow mechanical equipment efficiencies to be used to meet the performance-based approach to energy code compliance. This approach is based on the Proposed Home meeting the annual energy use cost budget established by the prescriptive path-based Reference Home.
I was asked to research the impact of RE166 on the performance-based approach to energy code compliance. I was paid to do the research, but the client asked me to determine what the impact would be- not make my research results fit their ideas.
Since I prefer evidence over emotion (stems from my work as a surveillance operative), I took this approach to finding the answer:
1 What is the question? For me, it was “Does allowing mechanical equipment efficiencies to meet the prescriptive annual energy use cost budget of the 2012 energy code have an impact on energy costs related to heating, cooling, and domestic water heating?” The follow-up question was “If so, what is the impact?”
2 What other work has been done on this? I found two valuable pieces of work. One document, produced by the Florida Solar Energy Center and authored by Philip Fairey, established a methodology for analyzing energy code compliance relative to a HERS Index, and the other document, produced by Pacific Northwest National Laboratory in 2012, established the methodology used by the Department of Energy to make a determination of the cost-effectiveness of residential energy code changes.
3 Experiment. Thanks to the methodologies uncovered in my preparative work, I was able to devise an experiment to simulate the impact of mechanical equipment efficiencies on energy costs for heating, cooling, and domestic water heating and determine the comparative impact to a home built to the 2012 energy code prescriptive path. The only variation between the control (2012 energy code Reference Home) and the experiment (Proposed Home) was the mechanical equipment efficiency and capacity. I performed the experiment simulation in 19 cities, spread across all 8 climate zones, and used 3 foundation types, 2 heating types, and 2 water heating types. I first ran the experiment and compared the current prevailing federal minimum efficiency standards (2012 energy code) with the federal minimum efficiency standards for mechanical equipment that go into effect in 2015. My second set of experiments compared the 2015 federal minimum efficiency standards to slightly more energy efficient mechanical equipment that is “state-of-the-shelf”.
4 Observation. In every single case, the use of mechanical equipment efficiency to meet the annual energy use cost budget of the 2012 energy code Reference Home resulted in a home that was more energy efficient on a cost-basis.
5 Review. After documenting my observations, I circulated them to a select group of colleagues who have demonstrated a willingness to challenge my ideas. This produced clarity in the final report.
The entire time I kept hearing my colleague from DOW, Dan Tempas, saying “It’s more important that the right answer is my answer, than my answer is the right answer.” The concept is to base your findings on evidence, not evidence upon your findings.
One of my observations that I found interesting: apparently, you can get away with murder in Miami, but get the death penalty for jay walking in Fargo. Homes built to the minimum prescriptive code standards zipped past the performance-based thresholds in Miami, but homes built to the minimum prescriptive code standards barely met the performance-based thresholds in Fargo.
I examined the arguments against RE166. It was difficult because most of the arguments are misleading and based on a fallacious understanding of how the performance-based approach to energy code compliance works.
They have laid outrageous claims of rolling efficiency levels back to pre-2009 energy code levels (not true) and that RE166 will cost consumers thousands of dollars because mechanical equipment efficiencies are not cost effective (also not true).
1 The Department of Energy (with the support of groups now opposed to RE166) has already made the determination that using improved mechanical equipment efficiencies is cost-effective for the consumer, and has adjusted the prevailing federal minimum efficiency standards accordingly with an effective date of January 2015 for heating and cooling equipment and April 2015 for water heating equipment.
2 The 2012 commercial energy code allows the use of improved mechanical equipment efficiencies to meet the annual energy use cost budget by using the prevailing federal minimum efficiency standards as the baseline in the Reference Building, while the 2012 residential energy code does not allow it by using the efficiency of the mechanical equipment in the Proposed Home as the baseline in the Reference Home.
3 The methodology used by the Department of Energy to determine the cost-effectiveness of proposed residential energy code changes includes using the prevailing federal minimum efficiency standards for mechanical equipment as the baseline in the Reference Home, exactly as proposed by RE166.
RE166 homes will inherently be more energy efficient than a prescriptive home built to the current 2012 energy code because the prevailing federal minimum efficiency standards increase in 2015.
These same actors who are now opposed to RE166 pushed for those federal minimum efficiency standards to go up because they are cost-effective for consumers! And now they are claiming they aren’t?
Since the Proposed Home has to meet the annual energy use cost budget set by the prescriptive-based Reference Home, it is IMPOSSIBLE for the Proposed Home to be less efficient (in terms of energy cost to the consumer- the metric used in the performance-based approach) than a home built to comply with the prescriptive approach to energy code compliance.
The fear-mongering and emotional intimidation tactics used by opponents of RE166 are disturbing. Their arguments indicate inconsistency in thinking, a gross misunderstanding of how the performance-based (house as a system) approach to energy code compliance works, and a denial of reason.
Unfortunately, many well-intentioned groups have fallen for these misleading claims. Probably as a result of these actors having “Save” or “Energy Efficient” in the names of their organizations- we tend to naively assume that the name reflects the character. And, like the king in the Scottish play, we are deceived.
Apparently these actors also forgot the purpose statement of the 2012 residential energy code:
“R101.3 Intent.
This code shall regulate the design and construction of buildings for the effective use and conservation of energy over the useful life of each building. This code is intended to provide flexibility to permit the use of innovative approaches and techniques to achieve this objective.” (http://publicecodes.cyberregs.com/icod/iecc/2012/icod_iecc_2012_re1_sec002.htm?bu=IC-P-2012-000014&bu2=IC-P-2012-000019, retrieved September 21, 2013)
I guess they only want flexibility and innovation allowed if it fits their biased, pre-determined views.
I strongly encourage rational human beings to support RE166 and other proposed energy code changes that provide flexibility and innovation while meeting the annual energy use cost budget (so the homes will not be less efficient). And if you’re not rational, I suggest taking a deep look at…never mind, irrational people are by definition incapable of critical thinking.
Just check out the source of the information you base your decisions on, evaluate them, and use good judgment to make up your own mind.