Is Savings by Design Title 24’s Saving Grace?

In a time where the State of California is (supposed to be?) pushing toward net zero energy buildings, Savings by Design has the opportunity to represent the future of California’s “Title 24” Energy Code.

Energy modeling in California is more complicated than it’s ever been. The recent revisions of the state’s energy code (Title 24, Part 6, or just “Title 24” to most) have definitely become more rigorous. However, I question whether they have actually helped us design more energy efficient buildings. It has definitely become more rigorous, as I’m sure you’ve heard and probably seen reflected in your consultants’ fees, but is it actually helping us design buildings that consume less energy?

Let’s look at a simple example of a real project that I worked on. It’s a new 4-story office building in the greater Los Angeles area. We were providing energy modeling services for code compliance with plans to submit to plan check in December of 2016, right before the  2016 version of the code came into effective on January 1st of 2017. After significant effort and several iterations of the model, we were able to get the heavily glazed building to comply with code (the 2013 version, remember). Then some things happened (or, actually, didn’t happen fast enough) and the plan check date was pushed into early 2017. Now our code compliant model isn’t meeting code anymore. Back to the drawing board, right? Not at all…

We took our CBECC-Com 2013 energy model, upgraded it to the new 2016 version of the software, fixed a few errors, and ran it. When everyone thought we would have to figure out how to squeeze another 10% or more off our energy use, the performance went UP by nearly that amount. That’s right; our model barely complied with the 2013 code; we ran the same exact model in the new, more “stringent” code, and it actually helped us!

Many of you are hypothesizing the reasoning behind that phenomenon. I’ve done a lot of that myself, and have a decent idea, but it really doesn’t matter, does it? This is a fairly representative project type. The code should simply require it to use less energy as we’re 3 years closer to zero net energy, and it does the opposite.

Just to entertain some of you, we can take this one step further. The 2016 version of the proposed model did, in fact, use less energy on an annual basis (TDV energy at least, but let’s not go there today). The building design didn’t change though, so the actual project won’t be any more efficient when it’s built and occupied. One could argue that the performance compliance reports will list mandatory and prescriptive measures that are now required, which will change the nature of the real project. This leads us to one of the biggest issues with the current Title 24 process… Code enforcement.

Just have a conversation with a local building official - one of the people responsible for enforcing a code that covers literally thousands of pages. Standards (289 pages), Reference Manuals (2,038 pages), Appendices (494 pages), Certificates of Compliance, Certificates of Installation, Certificates of Acceptance, and a whole “Energy Code Ace” website that tries to makes sense of all these documents that summarize and explain one another. The point being is that I spend the majority of my working week using energy codes and standards, and I have a hard time keeping it all straight. How could someone be expected to know ALL of the building codes and this vast and complicated energy code that changes every three years?

The energy code compliance process we currently have is not helping us get to net zero, in my honest opinion. What we need is a simpler code that regulates actual energy consumption - not a percent reduction from some imaginary baseline building. We need to leverage the knowledge and creativity of design teams to come up with holistic, integrated solutions to energy efficiency. None of this is accommodated by the current process. Instead, our innovation is wasted on developing scripting tools and workarounds to generate code compliance energy models from our REAL models (more to come on that later as well).

Now, to the point. Savings by Design (SBD) is a CPUC-funded program that incentivizes energy efficiency in new construction, nonresidential projects. And, it’s an excellent one, because most of the participating investor-owned utilities (IOUs) are actually engaged with the industry of professionals that focus on energy efficient building design. Savings by Design representatives attend local events that focus on energy modeling and building performance. They have technical staff that trains in the simulation tools that are being used, and they even perform their own preliminary analysis on occassion to support projects in their early stages. What all of this means, is that they understand what is happening in the industry they’re participating in, and they have the technical capacity to adapt the requirements of their program to accommodate real (as opposed to code compliance) energy modeling and the professionals behind it.

Subject to approval by SBD staff, utilities like SCE, LADWP (with SoCal Gas), and PG&E are accepting an “exceptional calculation method” as a means of calculating energy savings for incentive purposes. I’ve used this approach in the last three iterations of the state’s energy code, including the current one. The process is evolved, as the software tools-of-choice have in the last few years. In addition to the very basic and limited 2-dimensional (in all cases except one) “compliance” software engines, they also accept tools that professionals use for their “non-compliance” energy modeling; tools like eQUEST (slowly fading, but still an excellent choice) and IES Virtual Environment (my personal software of choice). Yes, teams are still required to document compliance with the energy code in the “typical” way, but now there is a real incentive for designing buildings using a real high performance design process (other than actual energy savings and LEED points, of course).

Now, why do I call Savings by Design Title 24’s “saving grace?” Well, it’s because I see it as a version of code compliance energy modeling that does what the state set out to do: save energy. Net zero, remember? It allows design teams to model things like natural ventilation, stratified air systems like UFAD, daylighting strategies other than one single flavor - things that will be absolutely required to get all new buildings to net zero by 2030. It does this while still following the Alternative Calculation Method (ACM) Reference Manual, which basically defines what code compliance software has to do. It does this while relying on qualified professionals that are good at what they do, rather than forcing an automatically generated baseline version of the proposed model that is the bottleneck of the current process.

I look at Savings by Design’s exceptional calculation method, and I see the future of Title 24. Imagine a world where you can focus your energy on an accurate representation of a developing building design, evaluating alternatives, fine-tuning natural ventilation controls, optimizing thermal comfort and making a real difference. And at the end, you don’t have to throw it in the recycle bin in lieu of using EnergyPro or CBECC-Com. It’s like owning a Tesla Model S that you can take out on the weekends to buy groceries or head to the beach, but you’re not allowed to take it on the freeway because law enforcement officials are suspicious that you might do something illegal with it. Okay, getting off-topic here.

Now, we’re not quite in the clear, even with Savings by Design. I’m working through a couple projects right now, and the knowledgeable and capable staff I mentioned earlier still have to cater to an Energy Division of the California Public Utilities Commission (CPUC) that is nervous to evolve the rules. Although many utilities are allowing this “non-compliance” energy modeling to determine energy savings for projects, they may still require a “compliance” version. Why would anyone want a second version of a well-built, accurate energy model that, by definition, becomes less representative of the actual design in order to document efficiency? Well, maybe they won’t; but maybe they will because it’s in a matrix in a document, and that would be new and different.

In closing, I’m obviously encouraged by how I’ve seen the Savings by Design program evolve. I will do what I can to continue to provide feedback and support to push things in a direction that are in the best interest of our portion of the industry, because that is the same direction that will lead to more efficient, net zero building designs. It will also happen to lead to building professionals that are happier and more fulfilled, because many of us do this work to make a positive impact - not just to get building permits or “points.”