In the past year or so, we had a few Title 24 clients who were interested in rebates from the New Solar Homes Partnership, an initiative offered through public utilities in the State of California. Since writing our earlier post we have discovered just how complicated a process this is, even more so now with the new Title 24 HERS reporting requirements. It really pays to plan ahead.
NSHP is only one of a dizzying array of rebates and incentives. The NSHP is part of the California Advanced Homes Project, which encourages greener, more efficient homes (not only solar). Some of these incentives, like the online rebates for EnergyStar appliance purchases, are targeted at individual homeowners. Other programs like the NSHP may be more easily handled by builders, developers, and solar vendors rather than by individual owners. Unless you have an unquenchable passion for paperwork, as an individual homeowner you may be better off going through a solar company, since you’ll have to use one anyway to obtain a solar system. An experienced solar company should already be familiar with the process (it’s something to ask them about).
Important Things to Know Upfront
The NSHP is for NEW homes only, and the main bar or litmus test is by how much you can exceed Title 24 requirements – either by 15% or 35%. It’s also specific to solar renewable energy – it doesn’t cover wind, water, or quasi-renewables like geothermal or fuel cells. (If you are retrofitting an existing home with solar, check with the California Solar Initiative.)
You will need the following consultants:
- Solar vendor
- Title 24 consultant who’s a CEPE
- HERS rater, with special NSHP certification
Obviously if you’re building a new home, you’ll have other professionals as well, including a licensed architect and a licensed general contractor. You might also consider a mechanical engineer with experience specifying and designing heating/cooling/water heating systems for renewable-energy buildings.
The NSHP rebate is specific to location and street address, and you should already have a proposed design for the home. You will need to be specific about your choices for mechanical, glazing, construction details, and appliances. Since all these features are explicitly called out in the application, any substitutions made during construction should be carefully reviewed. Even a seemingly minor change could necessitate a re-do of the Title 24 compliance report and/or parts of the NSHP application.
Before Applying for NSHP
The NSHP is handled through each local utility company, which in the Bay Area is PG&E. This list was taken from PG&E’s NSHP web page.
- The home must get service from PG&E. If needed, fill out an application for new service for the selected location.
- You’ll also need to fill out another PG&E application for Net Energy Metering.
- Read the NSHP Guidebook, available from the California Energy Center (CEC). It’s 73 pages long. The latest version of this book, along with the various forms, is available here.
- Get your Title 24 report (the CF-1R) done by a Certified Energy Plans Examiner (CEPE) using the performance method.
- Price out your solar system to a vendor whose name and address are registered with the CEC.
- Either the Title 24 consultant or the solar contractor uses the NSHP PV calculator, a free download, to get the expected performance analysis of your proposed solar system. This will go on the CF-1R-PV form, another CEC form. The PV calculator is a climate-specific performance modeler like the Title 24 modeling software, but it’s just for the solar system.
Forms and Paperwork – An Endless Supply
Before we get into the actual NSHP process, let’s familiarize ourselves with the various numbered forms that crop up at various points. Time is of the essence, because the NSHP doesn’t want to commit funds that will be tied up in projects that drag on for years.
Permit submittal phase
- CF-1R – Title 24 report completed by CEPE using performance method. It’ll need to beat the standard by 15% or 35% depending which NSHP tier you’re going for. Note any measures called out on the report as requiring HERS verification. For example, specifying insulation level in the Title 24 calcs doesn’t need a HERS field inspection, only a CF-6R installation certificate, but if you claim the quality of insulation installation (QII) credit on top of that, then you do need a HERS inspection. You’ll also have to specify your mechanical heating/cooling/water heating equipment and system design a lot sooner than you might be used to doing.
Construction drawings phase
- NSHP-1 – Reservation application form; this can also be done online. It’s not required for the permit submittal, but it’s good to get that going earlier rather than later.
- CF-1R-PV – output from PV calculator in step 6, done by solar vendor or CEPE
- NSHP Supporting Documentation – Every possible aspect of the project, including a full set of permit drawings, site map showing compass orientation, the CF-1R Title 24 report, drawings for electrical, mechanical, lighting, appliance specifications and EnergyStar certifications, and a copy of the solar contract.
- NSHP-2 – received after completing NSHP online reservation application, filled out incrementally over course of construction.
- CF-6R – one or more certificates of installation for each of the general energy efficiency measures specified in CF-1R. Completed by installer(s), probably subs of GC, for water heating, furnace, air conditioning, windows, ductwork, airtightness, insulation, lighting. Note that insulation may require HERS inspection prior to closing walls.
- CF-6R-PV – certificate of installation of solar system by installer, likely the same solar vendor or their sub
Note if you swap things out like mech or windows, especially for something cheaper, you might have to re-do the Title 24 report and add new measures to keep your 15% margin. Makes it difficult to do design changes in the field.
- CF-4R – One or more verifications completed by HERS rater, one per HERS inspection.
- CF-4R-PV – Completed by HERS rater, not sure what they look for exactly or if they actually test it.
- NSHP-3 – a 10 year warranty on the solar system
- STD-204 – filled out by party who receives payment for the solar system, probably the solar vendor
- IRS W-9 – from the PG&E customer
- Proof of PG&E hookup – no form is specified, so I don’t know what constitutes acceptable proof
NSHP – Actual Application Process
So you went through the “Before Applying for NSHP” checklist above and you’re good to go, right? Wrong! You haven’t even started to apply for the NSHP stuff. Listen my children and you shall hear, of the New Solar Home rebates oh so near. I came up with a flow chart of sorts, completely unauthorized of course.
The numbered steps below came out of the NSHP Handbook, but they’re not exactly the same as what’s shown on the diagram above, because the diagram includes items that aren’t NSHP-related – but which sometimes have to occur in tandem.
Step 0. Create an initial proposed design for the home.
Step 0a. Do Title 24 analysis and energy budget analysis. Try to optimize the energy budget, get it as small as possible. Make design or material changes if you have to. Remember you have to beat Title 24 by at least 15%.
Step 1. Choose your solar vendor and equipment. This will be a vendor who’s come up with a proposal that includes equipment such as PVs, inverters, and metering. The actual installers must be licensed.
Step 2. Complete an online reservation using your PG&E account or send in a hard copy reservation application form. This ensures that if eligibility requirements change after you’ve started this process, your hopes won’t be dashed in the middle.
Step 3. Do the PV calculation referenced in step 6 from previous “Before Applying” series.
Step 4. Refer to NSHP Handbook and send all required documentation thus far to PG&E. Supporting documentation includes site map, the PV calc, Title 24 report, Title 24 source files, PDF permit drawing set with title 24 info, electrical, mechanical, proof that all appliances are EnergyStar, solar contract.
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Step 5. Assuming that every possible “i” has been dotted, PG&E will review all this and send you an approval form called NSHP-2 stating the amount of funding that’s been approved. This form has several parts that are filled out during the course of construction by various parties. (My guess is PG&E fills out part 1, the solar installer fills out part 2, the HERS rater fills out part 3, and either or both of them may fill out part 4.) Note the expiration date on this form. You have to get through the entire project, meaning construction has to be completed and forms submitted, before this date. The implication is to send all subsequent forms at once because “there’s no guarantee” that info submitted piecemeal will be associated with the right project. (installers fill out CF-6R forms)
Step 6. Do the HERS verifications. HERS rater fills out CF-4Rs online for each verification or inspection. The PV inspection has to exactly match the PV calculations submitted earlier.
Step 7. Complete the remainder of form NSHP-2 by listing any modifications made to the equipment since the reservation was approved, and send the form back to PG&E. You also need the Ten year warranty form NSHP-3.
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Step 8. You might need to provide proof that system was actually hooked up to PG&E, meaning the building inspector has to approve it all.
Step 9. Yet another form, the STD-204, is required by the designated payee. This is specific to the payee, not the project so if you already filled one out for a previous project within the past year you don’t have to do it again unless of course your information changed.
Step 10. And PG&E customers need to provide an IRS W-9 form, probably this applies to businesses and corporations who need to show a Taxpayer Identification Number.
Nowhere in here are audits spelled out. The Title 24 reports that we submitted on behalf of our clients were reviewed with a fine-toothed comb against all other supporting documentation. I expect that PG&E has to verify everything on that report against all the drawings, mechanical, etc. That all happens on the PG&E side and is a black box. If there are any inaccuracies on the application, even down to the owner name listed on the Title 24 report, they can kick it back.
Nothing in here guarantees that there will actually be funds to cover the rebate.
Title 24 Model Versus Reality
In order to prove a minimum 15% compliance margin, the Title 24 consultant will need to use the Title 24 performance method, which is a specially approved energy modeling software package specifically used to demonstrate compliance with Title 24 requirements. Depending on the home’s projected energy budget, you may need to make design changes to the home in order to boost the compliance score. These could include additional insulation, better glazing systems, more efficient mechanical systems and appliances, or compliance credits for HERS testing. Having a more efficient home will also help reduce the size of the solar system needed.
Title 24 ignores certain real-world shading conditions including trees, adjacent buildings, and landforms. So, for the purposes of getting your 15% Title 24 compliance margin these things won’t matter, but for the purposes of actually having an effective and comfortable home, shading should be considered and is a crucial factor in solar designs. Having the house shaded will help with summer cooling; however, the area that will have the solar arrays should not be shaded, or you won’t get the full benefit from the solar equipment. Equally important to consider is the use of solar heat gain during the winter months.
One “gotcha” of sorts with Title 24 is that it’s very difficult to create an all-electric, all-solar home because Title 24 has penalties for electric resistance heat and water heating. I don’t think there’s a requirement that the home actually get all of its energy needs from solar, so it’s possible to submit for a home that uses solar power for household appliances, but uses a gas forced-air furnace for heating. It’s still important to make the home as energy-efficient as possible and to make the heating equipment as efficient as possible.
Alan Aurich, Elevation Architects:
In my opinion, the #1 reason anyone should consider alternative energy systems is from a personal value system, tied to their commitment to protect and preserve our environment. Measuring a system from a “monetary” standpoint is moot and it’s a cost outlay for life of the system. And, no matter what, there has to be a “point person” to manage the effort and coordinate the respective needs of each party.
- It’s a 12-24+ month process from start-to-finish.
- The cost/benefit factor is likely nil and most likely, a long-term expense similar to a car.
- The process relative to the paperwork is extensive and intensive. To date, we still have not received our rebate that was “estimated” to arrive 3 months ago, and PG&E continues to bill us for electricity (3 months now) after the system went live in September.
Geoff Campen, Klopf Architecture:
We actually worked with three programs: NSHP, GreenPoint Rating, and California Advanced Homes. We had to prepare several packages for these programs. For NSHP we gave them the following documentation:
- Construction documents
- Mechanical drawings
- Title 24 report and digital input files (2008 energy code, even though project was submitted under the 2005 code)
- GreenPoint Rating checklist
- Spec sheets for specific systems
- HVAC equipment
- Roofing components
- Solar equipment
- Glazing products
- HVAC equipment
We went through our solar company for most of it, which was Cobalt Power Systems, Inc. in Mountain View, CA. They took all our information, put the application together, and submitted it on our behalf – or really, on behalf of the owner. It’s not done yet, either. We began the NSHP process in early February of this year. Construction on the home began in March, with an expected completion of March 2011.
There may be big differences among solar companies in this regard. Some are full-service, while others are technically adequate but not up on things like rebate processes for incentive programs. The Cobalt guys were really good, and knew what to do right away. But there are so many incentive programs out there, even our builder, a Certified Green Building Professional, didn’t know about them all.
Klopf Architecture client:
When you hire full-service solar installers their initial estimate already includes a reduction for a CSI or NSHP rebate that will be paid directly to them by the state. I considered SolarCity (First Solar) and Cobalt Power Systems (SunPower), and selected Cobalt. Both companies have documentation specialists that work with brisk efficiency to gather all the necessary documentation.
All I did was put Cobalt’s specialist together with our architects, and made sure our general contractor selected a GreenPoint rater who is also a HERS rater. If SolarCity got the job, they would have hired the rater themselves. I sincerely doubt that most PV customers would really know or care whether their rebate was CSI or NSHP, to them it’s just initials on the installers’ bids, and I’m sure a year later few would remember which was which or what paperwork was required.
As for CA Advanced Homes, we wouldn’t even have known about that one at all if the Cobalt office director hadn’t told us about it. Because that is to be paid directly to us, we were left on our own to apply. But as we could afford to pay the architects to look into it, even that was relatively painless.
- The NSHP application was managed by Bonnie Corwin at Cobalt Power, with docs provided by Geoff Campen.
- The CAHP application was handled by Geoff Campen.
- Both are relying on reports by Miles Hancock (CalCERTS), and Mark English Architects for the Title 24 report.
- Acknowledgments also to SunPower and Monterey Energy Group
Stay tuned for a follow-up interview with this design client, a homeowner who cares enough to commission a custom-designed home that is practical, energy-efficient, comfortable, and beautiful without being outwardly showy or ostentatious.
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.