A Breakdown of Title 24 Part 6 Code Updates

By Bobby Almeida

Next year will bring another update to California’s well-known building code, Title 24, specifically Title 24 Part 6 the building energy efficiency standards. The Title 24-2019 standard will go into effect on January 1, 2020 and will apply to any project that goes in for its first plan check on January 1, 2020 or later. Title 24-2019 continues to raise the bar that its predecessors set—moving California toward a more energy efficient (and eventually net zero) future. Within Title 24 there are separate codes for low-rise residential, which the code defines as 3 stories or less, and all other types of buildings. We’re going to focus on the nonresidential code updates here.

But, before going into code updates it’s important to understand the three types of code requirements in Title 24: mandatory, prescriptive, and performance. Mandatory measures are just what they sound like, where every single building must meet that measure, unless they conform with an exception that is explicitly listed within the code. Prescriptive and performance measures depend on what approach your project is taking to comply with Title 24. The prescriptive path allows projects to meet each and every prescriptive requirement in the code in order to comply with Title 24, while the performance path allows projects to take a comprehensive whole building approach. With the performance path you can substitute lower performing glazing for higher performing HVAC, as long as the trade off is at least as energy efficient. Most new construction projects will take the performance approach, since it lets a project use a window to wall ratio (WWR) above 40%, have different envelope assemblies, and can avoid any potentially problematic prescriptive requirements. Tenant improvement projects regularly use the prescriptive approach since they only need to meet the lighting and HVAC requirements, but can use the performance approach as well.

The updates in Title 24-2019 fall into these categories as well. Of the major changes, all HVAC systems, whether a large air handler in an office building or a small fan coil in a hotel room, will require MERV 13 filters. Previously the requirement was MERV 8 filtration and that was in the California Green Building Code. MERV 13 filters are standard in commercial office buildings, so this change will have minimal impact for those building spaces. However, high-rise residential and hotel buildings typically use MERV 8 filtration, so this will be a major change for those spaces. Argento/Graham talked to a mechanical contractor who is installing MERV 13 filtration on all heat pumps in one of our high-rise residential projects. The mechanical contractor said that as long as the correct equipment is chosen during design and the design engineers account for the MERV 13 filters that it’s easy to build. All of the design engineers we know will easily be able to accommodate this change and design accordingly, so the change to MERV 13 won’t be too difficult. The only potential issue is that it might eliminate a few HVAC models as options, but we’re sure that all or most HVAC manufacturers will create a model that can handle MERV 13.

Another major change in the 2019 code is the reduction in allowed interior lighting power densities. The cuts are quite drastic compared to the 2016 code. For example, nonornamental lighting in a family restaurant will be limited to 0.50 watts per square foot, while the 2016 code allowed 1.0 watts per square foot. Open office areas will be limited to 0.60 watts per square foot while the 2016 code allowed 0.75 watts per square foot. The new allowances are all achievable – otherwise they wouldn’t be in the code – but it will take a thoughtful lighting design to meet code. One area where issues may arise could be for luxury projects with lighting designers. A darker color scheme and a high-end lighting design may not be able to achieve the required lighting power densities. The new code may force designs to make energy efficiency as important as illuminance and aesthetics.

Additionally, interior lighting is one of the items that can be traded off when a project takes the performance approach to compliance. Right now, most projects will easily meet the lighting power density requirements, which can allow that project to make a tradeoff elsewhere. One common energy tradeoff is for the WWR, since code limits the WWR to 40%. With the new lighting power density requirements projects won’t be able to take as much credit, which will require projects to decrease their WWR or to purchase higher efficiency HVAC systems. I can already hear architects practicing their HVAC sales pitches.

Another major change is that the energy code now covers more occupancy types. Specifically, I-1 and I-2 have been added, which cover hospitals, nursing homes, assisted living facilities, and much more. These occupancy types have a good number of exemptions throughout the code, but they are now covered and will require an energy efficient design.

There are many more changes to the 2019 energy code, so please reach out to Argento/Graham if you’d like to learn more or prepare your project for Title 24-2019.

Roddenberry Entertainment earns its first ENERGY STAR certification; Outperforms the LEED model and similar U.S. buildings on measure of energy efficiency

Roddenberry Entertainment Inc. in Los Angeles, CA has earned the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR® certification for superior energy performance. This first ENERGY STAR Certification reflects Roddenberry Entertainment’s continued commitment to excellence in energy efficiency and environmentally sustainable practices. The building is also certified Gold under the LEED for New Construction rating system.

Argento/Graham supported Roddenberry Entertainment through the certification process by benchmarking the building in ENERGY STAR’s portfolio manager.  The building received a high score of 93.

“Improving the energy efficiency of our nation’s buildings is critical to protecting our environment, “ said Jean Lupinacci, Chief of the ENERGY STAR Commercial & Industrial Branch. “From the boiler room to the board room, organizations are leading the way by making their buildings more efficient and earning EPA’s ENERGY STAR certification.”

ENERGY STAR certified buildings and plants are verified to perform in the top 25 percent of buildings nationwide, based on weather-normalized source energy use that takes into account occupancy, hours of operation, and other key metrics. ENERGY STAR is the only energy efficiency certification in the United States that is based on actual, verified energy performance Curious about actual, verified energy performance and predictive energy use, Argento/Graham analyzed the LEED model results alongside the actual energy data required to benchmark the building. The analysis showed interesting results: the predictive annual solar production and the actual production only differed by less than 10%, or 25,997 predicted kilowatt hours compared to the recorded of 24,850 kWh. The predicted use in electricity was very different. The predicted building use was 71,300 kWh while the actual was 42,424 kWh. This difference of -40.5% indicates that Roddenberry Entertainment uses significantly less power than its peers which may be attributed to occupant behavior or differences in actual operating schedules and number of occupants as compared to assumptions made while the project was in the design phase.

To date, tens of thousands of buildings and plants across all fifty states have earned the ENERGY STAR. For more information about ENERGY STAR for Buildings and Plants, visit www.energystar.gov/buildings

Argento/Graham is an official service provider for ENERGY STAR portfolio manager and is ready to help benchmark your building.

An Energy Comparison: LEED v3 / v4

While much of the focus of LEED v4 has been on the materials, the energy credits also experienced significant changes. One major new requirement is that the commissioning design review is a part of the fundamental commissioning prerequisite. This means that all LEED projects must engage a commissioning agent during the design phase. The minimum energy performance prerequisite also requires analysis to be done during the design phase, and the referenced energy standard has been updated to ASHRAE 90.1-2010. ASHRAE 90.1-2010 includes many new mandatory requirements, that all projects must comply with, such as controlled receptacles and daylighting controls. Luckily, most projects in California are likely to meet those mandatory requirements, as well as the commissioning design review, simply by complying with Title 24.

For LEED Commercial Interiors projects, the way energy efficiency points are awarded has been changed as well. In LEED v3, a project could earn all the points by prescriptively complying separately with the HVAC, lighting, and process load credits. In version 4, that option is still available, but a project cannot earn all the points available. In order to maximize energy efficiency points, a project will need to run a tenant level energy model using ASHRAE 90.1-2010.

Measurement and verification has also undergone a radical transformation. Projects will no longer be required to create and implement an M&V plan. In order to achieve the new Advanced Energy Metering Credit, projects will only have to install submeters on significant end uses. Additionally, a new prerequisite has been created which requires all projects to have building level energy meters. For most projects this won’t be a concern, but some campus projects will need to submeter out each building.

LEED v4 recognizes the variety of different services a high-quality commissioning agent can provide. Unlike LEED v3, where Enhanced Commissioning was all or nothing, LEED v4 has a few different Enhanced Commissioning options to choose from. Projects can choose to have their commissioning agent perform Enhanced Commissioning with or without Monitoring Based Commissioning. Additionally, projects using the building design and construction rating system can choose to pursue Envelope Commissioning as well.

What the Clean Power Plan Means for the Green Building Industry

By: Andy Ray

            In early August, the U.S. Green Building Council released a statement applauding the Obama administration for issuing the final rule of the Clean Power Plan that, for the first time, will place nationwide limits on emissions of carbon dioxide from power generation.[1] This historic plan aims to reduce domestic carbon emissions 32% by 2030 and is centered around three “building blocks”: 1) improve efficiency of current power plants; 2) increase dispatch of natural gas combined cycle plants; and 3) significantly expand the amount of electricity generated from clean energy sources.[2] Each of the three “building blocks” was assigned an applicable emission reduction value based on state and regional characteristics to establish state-specific emission limits for the electric generation sector. Collectively, these three blocks were determined to be the best system of capping carbon emissions generated by the electricity sector.

            Careful observers within the green building industry will note that demand-side energy efficiency measures, an important and low-cost option to reduce emissions, were used as the fourth building block in the draft plan, but were conspicuously removed from the administration’s final rule. In the CPP draft version, the formula used to establish state-level emissions limits included an annual emissions reduction of 1.5% annually from energy efficiency measures.[3] But following extensive comments from outside parties indicating that the energy efficiency block could become a legal vulnerability, the EPA selected not to incorporate it in the final rule.[4]

            So will eliminating the energy efficiency block affect sustainable building design and construction? It is easy to see why the initial reaction of many would be to assume that its elimination as a key block would negatively influence the green building industry and decrease the overall efficacy of the CPP—but numerous indications signal that this is unlikely to be the case. 

            The removal of the energy efficiency block by the EPA will simply alter the methodology used to determine the yearly emissions cap for the power sector. Even without the fourth energy efficiency block in place, EPA’s overall emissions reduction target in the final rule is actually two percent higher than what was announced in the draft phase. Secondly, despite its exclusion as the plan’s fourth building block, demand-side energy efficiency measures will continue to be allowed as a tool aiding states in achieving their prescribed emission reduction goals.

            Energy efficiency mechanisms are widely considered the lowest-cost option for achieving emissions reduction targets, and in some modeling scenarios, they can facilitate meaningful savings for consumers.[5] States will be able use various options that help reduce electricity consumption including: demand-response programs, energy-efficient construction and design, incentivizing high-efficiency lighting and appliances, and third party energy monitoring. Furthermore, within the pages of the administration’s plan, is the Clean Energy Incentive Program (CEIP), an optional provision that incentivizes early investment in energy efficiency and renewable energy projects located in low-income communities.[6] States participating in this program will receive double Emissions Rate Credits that can be used toward compliance in subsequent years. It is probable that the CEIP will be attractive for states, likely spurring special financing mechanisms that encourage renewable energy systems and green building developments; such as schools, offices, and hospitals, in regions that are sorely missing green infrastructure.

            Already, many states have policies that promote energy efficiency; and those with the most stringent and comprehensive measures – such as California and Oregon – will be distinctively ahead of the curve in meeting their carbon emission targets. The Clean Power Plan will transform the way America looks at energy production and indubitably usher in the next era of energy efficiency and renewable energy development. In the coming years, the green building industry is positioned to become a major beneficiary of the CPP as a growing number of states and communities adopt and expand energy efficiency and green building practices. But perhaps most importantly, is that just months before the United Nations Climate Change Conference, the United States has announced that we have finally recognized the need to become an international leader in developing solutions to reduce global carbon emissions. 

[1] USGBC CPP Statement, 2015

[2] EPA CPP - Final Rule, 2015

[3] EPA CPP - Draft Rule Fact Sheet, 2014

[4] Greenwire - 'Building Block 4' Cut Seen as Pre-Emptive Move for High Court, 2015

[5] http://www.c2es.org/publications/modeling-epas-clean-power-plan-insights-cost-effective-implementation

[6] http://www.epa.gov/airquality/cpp/fs-cpp-ceip.pdf