Why Does Title 24 Ignore Alternative Energies?

Why Does Title 24 Ignore Alternative Energies?

Posted on 13. Aug, 2009 by in Designing for Compliance

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Nearly every week, we are asked why Title 24 does not give credits for electric water heating if that electricity comes from solar or other self-generated power. In fact, it seems that many of the renewable energy developments occurring now are not fully recognized in Title 24, not even in the 2008 code. We’re in the position of telling people that their homes, which are designed to consume very little conventional power, may have trouble passing the Title 24 code if those homes rely solely on solar electric for all their home power, heating, cooling, and water heating needs.

So why does T24 continue to penalize electric resistance heat and water heating in solar homes? Why does T24 not give credits for self-generated power (geotherm, solar, wind, other)? And why can’t our utilities buy back excess power from customers who generate more than they use? Wouldn’t this help to reduce California’s grid load, save California homeowners money, provide entrepeneurial opportunities, and reduce American dependence on foreign oil?

Title 24 History

California’s energy standards were originally mandated in 1974 by the California legislature, through a piece of legislation commonly known as the Warren Alquist Act. This act created the California Energy Commission and authorized it to develop and maintain energy efficiency standards for new buildings, and it specifically requires that these standards be cost-effective “when taken in their entirety and amortized over the economic life of the structure.” (Title 24 2005 Residential Compliance Manual)

According to the Title 24 2005 Residential Compliance Manual, Title 24’s stated intentions are the following:

  • Save homeowners money
  • Keep homes affordable
  • Reduce strain on the power grid during peak times by reducing demand
  • Stabilize California’s economy by buffering against sudden price increases
  • Comfort (poorly insulated and drafty homes with oversized systems that cycle on and off are less comfortable)
  • Reduce environmental pollution
  • Reduce carbon emissions

California Energy Commission’s Response

I started with the California Energy Commission, which is responsible for creating and updating the Title 24 energy code. Why would the code ignore the potential of self-generated power to reduce demand for conventional power when our grid is already fragile? I spoke with Mazi Shirakh, P.E., M.B.A., a Senior Mechanical Engineer who serves as the Project Manager for Building Energy Efficiency Standards at the CEC, and who is also the Program Lead for the 2008 Standards update. Mr. Shirakh outlined the reasoning behind Title 24’s approach to alternative energies. (It is normally the Commission’s policy that individual staff members should not be named in articles and blogs, but in this case they’ve agreed to allow us to attribute directly.)

“The reason is that up until now, alternative energy technologies were too expensive when compared with more traditional energy-efficiency measures such as high-performance windows or air conditioners. While their costs remain high, PVs cannot demonstrate cost effectiveness as required by the law. We recognize that this is changing,” explained Shirakh.  “PVs are still expensive, costing around $8/watt. To install a 2Kw solar system costs around $16-$20K, whereas you can get a high-efficiency furnace or air conditioner for a lot less than that. However, the price of PVs has been steadily decreasing since the beginning of 2009. Assuming that this trend continues, there will be more possibilities for PVs in the future rounds of Standards. At around $2 or $3 a watt (including incentives) PVs would be much more competitive with traditional efficiency measures.”

Shirakh mentioned incentives such as the New Solar Homes Partnership, and I pointed out that such programs have nothing to do with Title 24’s internal scoring. If the intent is to reduce the load on the grid through less use of conventional power, why should an electric water heater that runs from PVs be scored the same as an electric water heater that runs on conventional power?

“The building must meet a certain efficiency levels first before PV or other on-site systems are considered. If we didn’t do this, there would be nothing to stop someone from building an inefficient structure and just slapping an array of PVs on the roof instead of other efficiency measures such as building insulation. And there’d be nothing to stop the owner from ripping out those PVs later on and running the building solely off the grid.” he replied.

OK, I’ll buy that for a dollar.

Alternative energy contractors are less inclined to accept this argument without comment, however. “That’s a spurious argument, in my opinion. Who’s going to take a building with a functioning solar system and rip it out?” said Gary Gerber of Sun Light and Power, a solar systems designer and installer. Another alternative-energy contractor, Greg Kennedy of Occidental Power, speculated that it was about centralized versus decentralized power networks. “Utilities are building big centralized power plants, with solar installations far out in the desert and then transporting the power over long distances. If that power were generated more locally, less of it would be lost during transmission. It’s really about who’s controlling the cash register.”

In a subsequent exchange, Shirakh clarified CEC’s position regarding Title 24’s approach to self-generated power: “Allowing proper credit for solar assisted electric water heating is one of the goals of the next round of Standards (currently known as the 2011 Standards). However, we need to be careful about how much credit is given to onsite generation measures; we still want to encourage buildings with efficient envelopes, mechanical, water heating, and lighting systems, even in the presence of PVs and other onsite generation systems. In addition, an energy efficient building will require a smaller solar system (less costs) and provides more comfort to the occupants. It should be also be noted that the Standards do allow a substantial credit for solar thermal water heating which can be combined with either natural gas or electricity. This is a mature technology and is widely available within the State.”

Shirakh was not familiar with fuel-cell technologies such as Doosan Fuelcell’s (formerly ClearEdge Power) product offerings. However, he assured me that if we did any Title 24 documentation for a project that used them, we could contact the CEC for assistance.

Does Renewable Energy Comply with Title 24?

So, how hard is it to get a net-zero home to comply with Title 24? “Most are quite easy, because they are relatively efficient buildings already,” responded Dave Knight of the Monterey Energy Group. “The coastal areas and the hills are OK, but it is significantly harder to get a net-zero home to pass in Central California. California’s central climate zones are very hot, and the A/C load kicks in.”

Knight added, “From the very beginning, Title 24 mandated that solutions be cost-effective. In the past, some systems such as solar thermal could supply 80-90% of a home’s space heating load, but were seldom cost-effective, and it was complicated to predict how they would work. But they’re not looking at the current prices or the latest incentives. In the last few years, the prices of solar PV have dropped by 20-25%. So there’s three things coming together now: more efficient buildings, lower PV prices, and new tax incentives.”

So What Can We Do About It?

“The Grid-Tied Solar Electric home that we discussed at the AIA in San Francisco a few weeks ago is unbelievably simple, reliable, and predictable. And it’s cost-effective today. No matter what our clients’ motivation is, whether it’s reducing carbon emissions, saving on energy bills, or reducing dependence on foreign oil, there’s an incentive for them to convert their home to GTSE,” Knight responded, and went on to urge the design community itself to take on the task of change.

“I think the AIA should take the lead in building and promoting Net-Zero Energy homes. I mean, a LEED certification can cost six figures and require what seems like thousands of meetings. By promoting Net-Zero Energy homes, the AIA could push their own agenda without waiting for the CEC to catch up.”

Why Can’t We Sell Back to the Grid?

What about people selling their excess power back to the utilities like they can in Germany? “There’s a difference between a feed-in tariff and selling back the excess through net metering. A feed-in tariff guarantees or fixes the rate at which power is sold back. Net metering simply measures how much energy is used versus replaced. But, any excess you produce is a gift to the utility,” said Gary Gerber.

“There are actually several bills that have come up for this in the past few years, including one that’s on the table right now. Allowing PV owners to sell excess would offer several benefits. For one thing, it promotes a cleaner environment because it uses no fossil fuels. But just as important is PV’s potential to reduce peak loads at the hottest times of the year, since peak cooling times are also when the sun is strongest.”

The Politics of Renewable Energy: Left and Right

Politically, there’s an unspoken divide between liberal and conservative approaches to power generation. Conservatives tend to push for nuclear power and offshore drilling, whereas liberals are more likely to promote clean solar energy and lifestyle changes. “We don’t care, it’s about what really works,” observes Green Compliance Plus founder Mark English. “Knee-jerk ideologies are not useful.”

There have been a few reported accidents, and safety is a major concern for both operation and waste disposal, but overall France seems to have a good nuclear energy model. A formerly oil-dependent nation, France invested heavily in nuclear power as a response to the 1973 oil crisis – now they actually EXPORT power. (Perhaps rather than dismissing it out of hand, we could seek to enforce accountability by requiring all nuclear executives and managers and their families to reside within a mile of their own power plants?)

Having said that, the ideological debate does tend to polarize along party lines. Solar power is viewed as an expensive boutique technology espoused by rich liberals like Al Gore who don’t always practice what they preach (remember when his Tennessee mansion turned out to have a huge carbon footprint, even after he wrote such reams on global warming? What were you thinking, Al?) It’s also possible that conservatives haven’t invested as much in renewables and thus don’t stand to profit from increased sales of renewable energy products and systems.

Who knows? When it comes to solar energy, I’d like to think that a chance to save money on energy bills and perhaps even make money as an entrepeneur, would be appealing to advocates of free enterprise. And, the opportunity for America to reduce dependence on foreign oil should appeal to political economists and xenophobes alike. What are we waiting for?

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About the author
 Rebecca Firestone has been working in the Bay Area since 1998 as a technical writer, business content developer, architectural filing lady, marketing director, and sorcerer’s apprentice.

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