from Damon R. Conklin, Director of Government Affairs, Sacramento Regional Builders Exchange
Greetings,
Please allow me to draw your attention to the draft Codes & Standards Enhancement (CASE) reports that have been released for consideration for the 2022 California Building Energy Code. The CASE Report, contain 43 proposed sub-measures of varying impact, some measures are mere compliances options, some are code clarifications, others are manufacturing standards for various kinds of equipment.
There are six measures identified to be a concern (potential high cost with low energy efficiency gains) to the commercial building sector. While there are opportunities for new projects created by these recommendation, there are concerns that added costs to new commercial and non-residential developments may cause some projects not to pencil out and be passed on.
Data regarding both the current use of the measures, and the potential cost would be most helpful in informing the CEC’s code adoption process which begins this fall. Our request for data and feedback are in bold at the end of each measure impact summary. Please respond and help make the 2022 Standards as practical as possible.
ISSUES OF CONCERN:
- Envelope: High Performance Windows: CE average of 1.0, with 5 climate zones below 1 (the full draft CASE Report for this measure is not yet available, and there is potential for additional revisions)
This measure calls for increasing window performance standards, both u-value and solar heat gain coefficients (SHGC). Fixed window changes: U-factor: 0.36 to 0.34, and SHGC: 0.25 to 0.22; and curtain wall or storefront: U-factor: 0.41 to 0.38, and SHGC: 0.26 to 0.25. Operable window performance values will remain the same as 2019.
Data request: What u-value and SHGC are you currently installing? What would be the cost impact of installing the proposed windows?
- Envelope: Roof Alterations: Average CE of 2 (the full draft CASE Report for this measure is not yet available, and there is potential for additional revisions)
For roof alterations the same cool roof standards apply as they would to new roofs, and now even simple roof recovers will require either meeting current insulation standards or, where that is not practicable, the measure will require insulation of at least R-8 to be installed.
Data request: What cost impact is added R-8 roof insulation to roof deck when performing minor roof repairs?
- Whole building air leakage testing: Climate Zones 3, 5, 6, 7, CE below 3
The CASE Authors have proposed new standards for building envelope air leakage performance. The Authors propose limiting air leakage to 0.30 cfm/ft2 from 0.40. In addition to reducing the air leakage performance standard, the Authors purpose much more stringent testing requirements wherein buildings that do not meet the performance standard will be tested, inspected, and an improvement plan will be developed. These requirements will also apply to building alterations and additions. The Authors do allow room for exceptions where existing buildings fail to meet the standard, allowing that the building may pass if all practical efforts have been made to reduce air leakage. Practical is not a distinctly defined term.
This measure has some questionable cost and practicality issues. In the case team’s assessment, the cost benefit ratio was less than 3 in several climate zones. A ratio below 3 would require a payback term of ten years or longer. This proposal also includes a requirement for vestibules in new construction, which will add significant upfront costs. However, the final cost-benefit analysis for this measure is not yet available.
Data request: What is the process for testing buildings for air leakage (air changes per hour? How practical is it to test a multi-tenant building when only a few spaces may be occupied? What are the costs for with air leakage testing? The CASE Authors propose new prescriptive requirements calling for all commercial buildings to include enclosed vestibules. Exceptions allow for revolving doors, and doors that open into spaces of less than 3000 sq. ft. This measure is pending further review, and cost effectiveness data is not presently available.
- Indoor lighting: Open ADR requirement has a CE of 1 on average; the measure performs poorly overall
This measure places new limits on occupancy based lighting controls, bringing new requirements to have occupancy-based lighting controls in all office spaces over 250 ft2, with requirements for subzone lighting dimming to no more than 20% of full intensity.
Data request: Has occupancy-based lighting controls been effective in new buildings and/or tenant improvements? What are the costs associated with occupancy-based controls?
- Service water heating and boiler controls: oxygen trim controls perform poorly with significant expense (CE of 1 or less in climate zones 6, 7, 8, 15)
This measure requires new equipment for oxygen trim controls for commercial boilers.
Data request: What are costs associated with installing oxygen trim controls for service boiler?
6. Refrigeration systems
Automatic door closures will be required for all commercial and retail refrigeration system, spanning from grocery stores, to walk-in coolers to refrigerated warehouses.
Data request: CEC study estimate cost for automatic door closures is $700 per door. If you have installed or bid automatic door closures, what are your estimated spelling
Again, thank you in advance for your attention and any feedback that you may be able to provide.
Best,
Damon R. Conklin
Director of Government Affairs
Sacramento Regional Builders Exchange
5370 Elvas Avenue ǀ Sacramento, CA 95819
Telephone: 916.442.8991 ǀ Cell: 916.290.3400
Email: dconklin@srbx.org ǀ www.srbx.org