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:
- 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?”
- 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.
- 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”.
- 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.
- 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).
- 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.
- 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.
- 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:
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.