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.
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 […]
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 […]
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.
Free Ridership
Free ridership is a theory that has taken the energy code universe by storm. Perhaps by stormtroopers would be a better analogy. Free ridership basically is a theory that doesn’t give credit to beyond minimum performance- essentially saying, “You are already performing beyond our minimum expectations, so why should we reward you?”
If we were to apply the theory of free ridership to an academic setting, we would gauge performance by this grading system: everyone gets either a C or an F. No more academic honor rolls, no more scholastic societies, no more Dean’s List. No rewards in the form of scholarships, certificates, or extracurricular activities. It’s now a simple game of “Do the least you can to pass” or “You didn’t meet the minimums to pass”.
If we were to apply the theory of free ridership to an athletic setting, we would set benchmarks for athletic performance. In track and field, for example, we would set a maximum time benchmark for the 100-meter sprint; all the athletes who are faster than the benchmark time get the same medal, while those who are slower than the benchmark time get no medal at all.
In both of these competitive settings, free ridership ignores some pretty basic human psychology. When it comes to performance, people are either intrinsically motivated to perform or extrinsically motivated.
Extrinsically motivated people do the least they have to in order to survive. For their performance to improve, external forces have to act to overcome their inertia to force them to change, to push them in the direction of the desired behavior.
Intrinsically motivated people, on the other hand, want to perform better. They are constantly seeking to improve, to master their craft, to become the best at what they do.
Anyone who doesn’t believe home building is a competitive field should go see a doctor, preferably one who specializes in restoring brain function.
From an energy code perspective, the prescriptive path for energy code compliance was designed for extrinsically motivated builders. The prescriptive path forces builders to change their behavior, pushes them to improve the energy efficiency of buildings through the external force of regulation.
The performance path was designed for intrinsically motivated builders. It set the baseline at the prescriptive path level, but gave builders the freedom to do better than the minimum required by regulation. In fact, the builders would be rewarded for choosing to improve the energy efficiency of buildings without being forced to.
Then, in 2009, the theory of free ridership hit the energy code universe, led by stormtroopers disguised as energy efficiency advocates. The theory of free ridership took away the freedom to improve by removing the mechanical equipment trade-offs. The stormtroopers reasoned that builders shouldn’t get credit for something they were going to do anyway and forced an extrinsic motivation
mechanism onto intrinsically motivated builders. Holy cow!
We know what happens when extrinsic forces are applied to intrinsic-minded people. They first reject the idea and actively oppose it; then, as more external force is applied to overcome the opposition, they sullenly comply; finally, their innovative spirits crushed under the jackboots of excessive regulation, they accept their fate and new reality.
However, for some the spark of rejection ignites a fire of opposition- and since they are by nature motivated internally and are innovative, they devise a mechanism to allow them to continue to improve the energy efficiency of buildings without having to rely on the force of external regulation.
This scenario played itself out during the last ICC code hearings and resulted in the inclusion of an energy rating index as a third compliance option.
Free ridership has an unintended (perhaps) consequence of demotivating high performance. I say “perhaps” because it may not be unintended.
When free ridership is applied, performance will predictably go down to the lowest level allowed. In the performance path for energy code compliance, this lowered performance level can then be used as the pretense for increasing regulation, pushing intrinsically motivated builders into the extrinsic, prescriptive path.
Who benefits from this? Not the consumers, who will have to bear the increased cost for marginal performance improvements. Not the builders, who will incur the costs in the face of declining sales and profitability. Not the code officials, who have a hard time enforcing regulations already on the books.
The beneficiaries of the theory of free ridership are the traditional insulation and glass manufacturers who gain a captive market of builders who are forced by regulation to purchase their products at the price demanded by the manufacturers.
The other beneficiaries of the free ridership theory are the organizations funded by the manufacturers who promote this theory. Follow the money trail, and you will find many stormtroopers disguised as advocacy groups.
These advocates need to remember the lessons of history: when the internal motivation to perform is supplanted by the external force of regulation, performance will sink to the lowest level, not rise to the highest level. When best practices become minimum standards, best practices evaporate along with innovation unless another alternative path appears.
Free ridership stifles innovation while filling the coffers of those who are extracting maximum value out of the American Dream.