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	<title>Green Compliance Plus - Mark English Architects &#187; Project Management</title>
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	<description>covering green building compliance issues</description>
	<lastBuildDate>Mon, 30 Jan 2012 17:47:23 +0000</lastBuildDate>
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		<title>QII HERS Credit Now Allows Open Cell Spray Foam</title>
		<link>http://greencomplianceplus.markenglisharchitects.com/technical/insulation/qii-hers-credit-now-allows-open-cell-spray-foam/?utm_source=rss&#038;utm_medium=rss&#038;utm_campaign=qii-hers-credit-now-allows-open-cell-spray-foam</link>
		<comments>http://greencomplianceplus.markenglisharchitects.com/technical/insulation/qii-hers-credit-now-allows-open-cell-spray-foam/#comments</comments>
		<pubDate>Mon, 19 Dec 2011 18:08:46 +0000</pubDate>
		<dc:creator>Rebecca Firestone</dc:creator>
				<category><![CDATA[Insulation]]></category>
		<category><![CDATA[Project Management]]></category>
		<category><![CDATA[Regulatory Changes]]></category>
		<category><![CDATA[HERS rating]]></category>
		<category><![CDATA[Net-Zero Energy]]></category>
		<category><![CDATA[spray foam]]></category>

		<guid isPermaLink="false">http://greencomplianceplus.markenglisharchitects.com/?p=1321</guid>
		<description><![CDATA[This news flash about a seemingly obscure topic is of immediate importance to all our architect Title 24 clients -and it&#8217;s good news for a change. The Quality of Insulation Installation credit is a HERS test that can help design projects to achieve Title 24 energy compliance, and we&#8217;ve had a couple of nasty surprises [...]]]></description>
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			<a  href="http://api.tweetmeme.com/share?url=http%3A%2F%2Fgreencomplianceplus.markenglisharchitects.com%2Ftechnical%2Finsulation%2Fqii-hers-credit-now-allows-open-cell-spray-foam%2F"><br />
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<p>This news flash about a seemingly obscure topic is of immediate importance to all our architect Title 24 clients -and it&#8217;s good news for a change. The Quality of Insulation Installation credit is a <a  title="HERS tests explained" href="http://greencomplianceplus.markenglisharchitects.com/interviews/inspections-title-24-compliance/" target="_blank">HERS test</a> that can help design projects to achieve Title 24 energy compliance, and we&#8217;ve had a couple of nasty surprises with it in the past.</p>
<p>Apparently, up until around yesterday, the <a  title="California Energy Commission web site" href="http://www.energy.ca.gov/" target="_blank">California Energy Commission</a> did not officially recognize the QII test as valid for open-cell spray foam. Our insulation expert <a  title="Link to insulation interview with James Morshead" href="http://greencomplianceplus.markenglisharchitects.com/discussions/building-techniques/home-insulation-title-24/" target="_blank">James Morshead</a> of <a  title="SDI Insulation web site" href="http://www.sdi-insulation.com/" target="_blank">SDI Insulation</a> actually sent me an urgent email yesterday with the news, saying:</p>
<p style="padding-left: 30px;"><span id="more-1321"></span><em>Today the California Energy Commission stepped out of the 1980&#8242;s and into the 1990&#8242;s! The 1/2 pound density spray foam QII check list has finally been approved after long delays.</em></p>
<p style="padding-left: 30px;"><em>There will be further revisions and refinements but our State has finally caught up in its own way. They have finally acknowledged what the rest of the country has known and what we have known in our area for years; spray foam works whether its closed cell 2 pound density or open cell 1/2 pound density.</em></p>
<p style="padding-left: 30px;"><em>Now on to fixing the U-Value tables!</em></p>
<h2>Active lobbying at the CEC is necessary</h2>
<p>As usual, James was an endless trove of insider information. Apart from the news itself, the way that this came about was very revealing of the CEC&#8217;s  inner working processes. Most of us don&#8217;t understand how or why regulations are the way they are, or how agencies like the CEC solicit input from the public. Apparently one must be prepared to show up in Sacramento at multiple hearings, cultivate deep relationships with CEC staff, sift through the raft of proposed changes for the few items that might be relevant to your industry or situation, and be prepared to pounce on proposed changes with a formally structured submittal process. In other words, hire a full-time lobbyist.</p>
<h2>A QII teaching case with the New Solar Homes rebate</h2>
<p>We&#8217;ve run into some issues on the QII test before, where we&#8217;d called it out for extra credit on a Title 24 report on a project that was going for the New Solar Homes rebate. The house had to beat Title 24 by 15% to qualify. James Morshead was actually the insulation installer on that job, and clearly remembered how the HERS rater &#8211; NOT one of our <a  title="Green Compliance Plus Affiliate HERS Raters" href="http://greencomplianceplus.markenglisharchitects.com/title-24-services/affiliates/" target="_blank">Green Compliance Plus Affiliates</a> &#8211; flatly refused to accept the low-density spray foam. Closed-cell was fine, but open-cell? No way. This was maybe the first time we&#8217;d ever used the QII credit, and nobody, including our other HERS raters, could tell us much about this obscure little omission that suddenly threatened the validity of the project&#8217;s energy compliance documentation &#8211; and the NSHP rebate. There was much tearing of hair and gnashing of teeth all around.</p>
<div id="attachment_1326" class="wp-caption alignnone" style="width: 550px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/open-closed-closeup.jpg" class="thickbox no_icon" rel="gallery-1321" title="open-closed-closeup"><img class="size-full wp-image-1326" title="open-closed-closeup" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/open-closed-closeup.jpg" alt="open closed closeup QII HERS Credit Now Allows Open Cell Spray Foam" width="540" height="245" /></a><p class="wp-caption-text">This close-up shows examples of open cell and closed cell spray foam, also known as low-density and high-density foam. Each cell in the high-density foam is closed, making it a better air barrier - which increases its insulating value.</p></div>
<p>&nbsp;</p>
<h2>Whys&#8217; this QII change so darned important?</h2>
<p>What are the ramifications of this change and how did it come about? <span style="color: #3366ff;">&#8220;The recognition of open-cell spray foam has been in process for six and a half years,&#8221;</span> said James. <span style="color: #3366ff;">&#8220;We at SDI didn&#8217;t know how the CEC process worked. We thought the CEC would be actively looking at the market to incorporate new developments in a proactive way. But they&#8217;re not set up to do that. They&#8217;re set up to be reactive, influenced by lobbying input from stakeholders in the marketplace.&#8221;</span></p>
<p>He mentioned a long-ago fight between manufacturers of cellulose and fiberglass insulation, each of whom pushed to have their own products recognized as higher efficiency (higher R value) than the other. <span style="color: #3366ff;">&#8220;That&#8217;s normal business. The CEC is a government agency, and that means that they&#8217;re encumbered themselves by a lot of regulatory process. They&#8217;re restricted by the system themselves. They rely on input from competing parties, and they solicit information by saying, &#8216;We want your input.&#8217; They rely on the stakeholders to approach them and provide the necessary technical information.&#8221;</span></p>
<p>But presenting this input to the CEC can be an uphill battle. James mentioned meetings that would be cancelled without notice, web site meeting schedules that were not updated to reflect changes or cancellations, and a very skeptical audience.<span style="color: #3366ff;"> &#8220;They&#8217;re coming from an analytical and academic standpoint, but they&#8217;re NOT in the field.&#8221;</span> And that&#8217;s the main point of this discussion, is that until the CEC actually went out to see a low-density spray foam installation, they didn&#8217;t believe it worked AT ALL. <span style="color: #3366ff;">&#8220;They were writing regulations without ever having seen it in action.&#8221;</span></p>
<p>James went on to emphasize that he didn&#8217;t fault anyone at the CEC, in fact he admired their work and didn&#8217;t envy their task. They&#8217;re overworked, underfunded, well-intended, and very committed to the overall goals of helping California to achieve greater energy efficiency. They are doing their absolute best within cumbersome bureaucratic processes that they can&#8217;t change, either. To get an an idea of how slow the cycles are for code revisions, consider that the current version of the California energy code, the 2008 code, actually didn&#8217;t go into effect until 2010. And, some of its provisions weren&#8217;t enforced across the board until October of 2011.</p>
<h2>Meritage Homes &#8211; a study in foam</h2>
<p>Then we got on the topic of <a  title="Meritage Homes web site" href="http://www.meritagehomes.com/builder" target="_blank">Meritage Homes</a>, a high-end home developer who was apparently instrumental in adopting and demonstrating the real value of spray foam. Meritage&#8217;s Green FAQ page actually talks about the building envelope as separate from the appliances. James told me that Meritage had decided to use 100% spray foam in all its new developments. Their homes weren&#8217;t selling, because of the economy of course &#8211; not because the homes were bad. Nobody was buying anything, no one could get financing.</p>
<p><span style="color: #3366ff;">&#8220;But then, someone convinced them to foam their homes. The first batch was in Houston, TX. And the spray foam was so effective as an insulator that it ended up causing them some problems early on. Suddenly, all the A/C units in the foam-insulated homes were grossly oversized! Short cycling and such. And they had mold problems as well. But they also realized: OMG! this foam works way beyond the calcs!&#8221;</span></p>
<div id="attachment_1325" class="wp-caption alignnone" style="width: 550px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/meritage-home-example.jpg" class="thickbox no_icon" rel="gallery-1321" title="meritage-home-example"><img class="size-full wp-image-1325" title="meritage-home-example" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/meritage-home-example.jpg" alt="meritage home example QII HERS Credit Now Allows Open Cell Spray Foam" width="540" height="336" /></a><p class="wp-caption-text">Meritage Homes is a high-end home development company that has implemented energy efficient building envelopes as part of the core design.</p></div>
<p>And that&#8217;s where we get back to the CEC, and the California energy code, which has all sorts of tables and appendices with the allowable thermal values that you can use for various types of wall assemblies and insulations: wood frame, metal frame, etc. (They even have an appendix table for straw bales now.) So, even if your insulation is NASA-quality, the CEC&#8217;s Joint Appendices might disallow the use of its true performance capabilities when doing home energy calculations. Which isn&#8217;t really fair, considering how difficult it&#8217;s been to get even ordinary home designs to meet current California energy standards.</p>
<h2>The deconstructed home as sales tool</h2>
<p>Most of the time, developers will have a few finished-off model homes that prospective buyers can walk through to see what their home will eventually look like once it&#8217;s built. But Meritage did something different. They had a model home with cutout walls to show the interior building assemblies, including studs, wiring &#8211; and spray foam insulation. <span style="color: #3366ff;">&#8220;I call it the <a  title="Deconstructed home article link" href="http://www.housingzone.com/professionalbuilder/article/meritage-builds-%E2%80%98deconstructed%E2%80%99-home-demonstrate-green-features"><span style="color: #3366ff;">deconstructed home</span></a>,&#8221;</span> said James. <span style="color: #3366ff;"> &#8220;People now are smarter, more educated about building and energy efficiency. They want to see what&#8217;s inside. And sales took off! It was a totally new way to sell houses. Local building inspectors liked it, too.&#8221;</span></p>
<p>The homes weren&#8217;t selling for more money, but they were selling a lot faster &#8211; and, to investors, time is money. The quicker you can recover an investment, the less financing costs you have.</p>
<div id="attachment_1324" class="wp-caption alignnone" style="width: 421px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/meritage-deconstructed-home.jpg" class="thickbox no_icon" rel="gallery-1321" title="meritage-deconstructed-home"><img class="size-full wp-image-1324" title="meritage-deconstructed-home" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/meritage-deconstructed-home.jpg" alt="meritage deconstructed home QII HERS Credit Now Allows Open Cell Spray Foam" width="411" height="282" /></a><p class="wp-caption-text">By showing a &quot;deconstructed home&quot; rather than the usual finished showcase model, Meritage Homes has educated homebuyers on construction techniques and efficient building envelopes. This image shows a deconstructed Meritage home from one of its San Antonio developments, as shown on housingzone.com.</p></div>
<h2>CEC&#8217;s focus on new construction ignores issues for remodels</h2>
<p>Then our conversation touched on another issue with the current California energy code, and that is its almost obsessive focus on NEW construction. One goal at the CEC is for all new homes built after 2030 should be Net Zero. But remodels to existing homes also impact the energy grid, and at least in California, remodels right now represent a significant portion of current construction activity. (This is according to James &#8211; I haven&#8217;t yet found any data specifically comparing either dollars spent or number of projects of each type, in CA).</p>
<p>Sometimes this results in a very artificial situation when we try to show compliance for a remodeling project. It becomes an exercise in hoping that the project qualifies for prescriptive and we don&#8217;t have to run an energy model. For example, if a remodel is not adding any square footage, but the total glazing area is over 20% of the floor area, there are situations where the project just doesn&#8217;t qualify for prescriptive compliance. And let&#8217;s say that this is a low-budget project; they&#8217;re changing out the heating system and enlarging a couple of windows and leaving the rest alone, maybe it&#8217;s mainly an interior remodel which doesn&#8217;t affect the building envelope.</p>
<p>Well, there are times we&#8217;ve had to run a whole-building model that included all portions of the existing home that aren&#8217;t being upgraded, but which aren&#8217;t built to current energy standards. It&#8217;s easy to go down a path of adding new energy measures that not only add to the cost of the project, but which can just get ridiculous. Open more existing walls to re-insulate? You could trigger a seismic upgrade. Replace all the windows? Well, maybe the old windows were still perfectly good, why throw them away? Is that &#8220;sustainable building&#8221;? I&#8217;ve spent hours reading the Residential Compliance Manual&#8217;s sections on alterations and remodels, and sometimes writing to the CEC, to find out what&#8217;s really allowable.</p>
<div id="attachment_1322" class="wp-caption alignnone" style="width: 368px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/contortionist.jpg" class="thickbox no_icon" rel="gallery-1321" title="contortionist"><img class="size-full wp-image-1322" title="contortionist" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2011/12/contortionist.jpg" alt="contortionist QII HERS Credit Now Allows Open Cell Spray Foam" width="358" height="500" /></a><p class="wp-caption-text">Trying to get a small remodel to pass California Title 24 compliance can be more agonizing than modeling new construction. This vintage contortionist image is from &quot;The Circus, 1870-1950&quot; published by TASCHEN.</p></div>
<h2>QII checklists for each type of insulation didn&#8217;t include one for open-cell spray foam</h2>
<p>James reminded me that the HERS rater has to follow different QII checklists based on which type of insulation is used in the project. So there&#8217;s one QII checklist for fiberglass batt insulation, and a different checklist to use for blown-in, etc. Here&#8217;s a <a  title="QII checklist description from ConSol" href="http://www.consol.ws/builder-resources/insulation.php" target="_blank">nice checklist writeup</a> from ConSol, an energy group based in Stockton.</p>
<p>This checklist does not affect allowable R-values used in the Title 24 performance calculations. All it does is say that insulation should be installed evenly with no air gaps, empty spots, or compression, and that wall cavities should be sealed to limit air flow through permeable insulation types. The extra credit is really a make-up because the assumption is that typical insulation installation procedures are so shoddy that substandard installations are the norm rather than the exception. So, what&#8217;s not to like about open-cell spray foam exactly? And yet, because the CEC had no official checklist that was specific to open-cell, and they didn&#8217;t want to lump open-cell and closed-cell together, the omission has led many HERS raters to conclude that low-density spray foam was simply not allowed for the QII credit. That may in fact have been the official CEC policy, too.</p>
<p>Some HERS raters have very extensive backgrounds in building efficiency, construction, and green building; others just don&#8217;t have the same depth of knowledge. That&#8217;s one reason we chose to list some HERS raters on Green Compliance Plus who we felt had a better grasp of the underlying principles behind Title 24 energy compliance. Our HERS rater affiliates are people with multiple credentials: some are HERS and GreenPoint Raters, some also have CEPE certification, and most have other creds ranging from Energy Star to BPI to LEED for Homes. They already have experience working with integrated project teams on custom home projects, and are more proactive about anticipating potential situations ahead of time or recommending solutions instead of just showing up for the inspection and saying, &#8220;Well, you fail, and there&#8217;s nothing I can do to help. You won&#8217;t get your rebate after all. &#8216;Bye, now.&#8221;</p>
<h2>The CEC doesn&#8217;t always realize these ramifications until they&#8217;re pointed out</h2>
<p>On the above mentioned NSHP case study, when James brought this up to the CEC staff and engineers, they were appalled. They had never dreamed that their policies would ever lead to a situation like this. The HERS rater had said, rather erroneously, &#8220;This product doesn&#8217;t work. Therefore, it&#8217;s not allowed.&#8221; What he really should have said was, &#8220;This product doesn&#8217;t have an authorized CEC checklist. And it&#8217;s still not allowed.&#8221;</p>
<h2>Checks and balances to prevent cheating are well intentioned, but they can really gum up the works</h2>
<p><span style="color: #3366ff;">&#8220;The CEC really wants to discourage cheating,&#8221;</span> said James. There are certainly more steps to verification now than in the 2005 code. The whole <a  title="Green Compliance Plus article on CalCERTS registry" href="http://greencomplianceplus.markenglisharchitects.com/regulatory-changes/calcerts-registry-now-required-for-all-residential-projects" target="_blank">CalCERTS registry process</a>, with online filing of  the tandem forms for the Title 24 energy compliance report, the installation certificates, and then the HERS certificates, is a great idea but a royal pain in the bum. The online workflow is especially agonizing for custom remodel projects. The CalCERTS support folks are very nice and they also have to follow a ton of regulations that attempt to cover every possible home construction scenario; they&#8217;ve never had to consider a different workflow for custom homes where an architect is directly involved.</p>
<p>The code update process is complex and unforgiving, not unlike San Francisco&#8217;s planning and approvals process.</p>
<p>So &#8211; what if someone wants to advocate for, say, a better attention to remodels, or to custom architect-designed homes? You&#8217;d better have a full-time staff person on the job. <span style="color: #3366ff;">&#8220;The process is so cumbersome, with hearings, submittals, and a lot of 45-day language,&#8221;</span> said James. (Really it&#8217;s just like the SF planning process) <span style="color: #3366ff;">&#8220;It&#8217;s really arcane &#8211; miss something and you&#8217;re dead.&#8221;</span></p>
<p>Other industries have their own issues to push for in the energy code. <span style="color: #3366ff;">&#8220;HVAC, energy consultants, builders… there are a few people who practically sleep in their cars down at the SMUD building in Sacramento.&#8221;</span></p>
<p>It helps to establish a good rapport with the CEC staff, who got high marks from James for dedication and responsiveness. <span style="color: #3366ff;">&#8220;If you know the system really well, you can know which events are important, but you can&#8217;t tell just by looking at the CEC site. It&#8217;s a labyrinth, and you need a guide. Try to have a relationship with the CEC staff. They can help you get your voice heard.&#8221;</span></p>
<h2>Is the Net Zero goal realistic and achievable by 2030?</h2>
<p>James thinks that the goal of having all new homes built in California after 2030 be Net Zero Energy is unrealistic, and not the best way to reduce overall building energy use statewide. <span style="color: #3366ff;">&#8220;NZE should be affordable to more people than it is right now. We should be making it easier for people to comply even as we tighten the standards. It would be better to reduce energy consumption by 40-50% rather than try for some exotic concept like Net Zero. Go for more basic stuff &#8211; air sealing, HVAC sizing, more credit for unventilated roof assemblies.&#8221;</span></p>
<p><span style="color: #3366ff;">&#8220;Net Zero Energy is a great idea,&#8221;</span> he continued.<span style="color: #3366ff;"> &#8220;But in the construction industry, there are so many different kinds of people involved. There are builders large and small, plan checkers, building inspectors, HERS raters, architects, energy consultants… no one knows how to do it right yet when it comes to energy compliance. Right now, this education is being force-fed into the system when people aren&#8217;t ready. NZE is such a complex concept, it requires a very integrated approach. If you push it on people too fast, it&#8217;ll be a disaster in the implementation.&#8221;</span></p>
<p>I can&#8217;t argue with him there.</p>
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		<item>
		<title>Title 24 Compliance for Alterations and Remodels</title>
		<link>http://greencomplianceplus.markenglisharchitects.com/technical/designing-compliance/title-24-compliance-alterations-remodels/?utm_source=rss&#038;utm_medium=rss&#038;utm_campaign=title-24-compliance-alterations-remodels</link>
		<comments>http://greencomplianceplus.markenglisharchitects.com/technical/designing-compliance/title-24-compliance-alterations-remodels/#comments</comments>
		<pubDate>Mon, 30 Aug 2010 19:55:31 +0000</pubDate>
		<dc:creator>Rebecca Firestone</dc:creator>
				<category><![CDATA[Designing for Compliance]]></category>
		<category><![CDATA[Heating and Cooling]]></category>
		<category><![CDATA[Project Management]]></category>
		<category><![CDATA[Windows and Glass]]></category>
		<category><![CDATA[Additions in Title 24]]></category>

		<guid isPermaLink="false">http://greencomplianceplus.markenglisharchitects.com/?p=880</guid>
		<description><![CDATA[Don't say we didn't warn you. The new Title 24 is tough! In past articles, we harped on the HERS verifications as a way to earn credits towards Title 24 compliance for those hard-to-pass houses. However, there's another angle that needs attention: issues for additions, alterations, and remodels.]]></description>
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<p>Don&#8217;t say we didn&#8217;t warn you. The new Title 24 is tough! In past articles, we harped on the HERS verifications as a way to earn credits towards Title 24 compliance for those hard-to-pass houses. However, there&#8217;s another angle that needs attention: issues for additions, alterations, and remodels.</p>
<p>(Above image shows a whole-house remodel and addition by Mark English Architects. Photo: Michael O&#8217;Callahan)</p>
<p><span id="more-880"></span><span style="color: #333399;"><strong>When does a remodel need to show Title 24 compliance?<br />
</strong></span><br />
When the changes impact the exterior building envelope, the heating/cooling/water heating systems, or when you&#8217;re adding conditioned area or volume. Envelope changes include new walls, replacing windows, and adding or enlarging windows. System changes include upgrading a furnace, changing the type of heating/cooling system, re-doing the ductwork, or upgrading the water heater. There are other circumstances like changing the lighting that may require Title 24 compliance. The focus is on conditioned space only, so garages and sun porches are not counted.</p>
<p><span style="color: #333399;"><strong>When do you NOT need a Title 24?</strong></span></p>
<p>When all changes are internal and don&#8217;t impact the energy performance of the building. For example, if you move a group of interior walls but leave the furnace alone.</p>
<p><span style="color: #333399;"><strong>What are the methods of showing compliance?</strong></span></p>
<p>There are two main methods: prescriptive and performance. The prescriptive method works just like a doctor&#8217;s prescription, with mandatory minimums for things like insulation or glazing performance. We do a little of that, but much of the time it&#8217;s fairly simple and many architects just do it themselves. The downside is that it&#8217;s less flexible &#8211; there are minimums, but it&#8217;s harder to get credit for exceeding those minimums in some areas in order to make up for shortcomings in others.</p>
<p>Not all remodels will qualify for prescriptive compliance. For example, if glazing is more than 20% of the floor area, or more than 5% of the glazing is on the west, then the project may need to use the performance method. The performance method is what we do, using a CEC-approved software modeling program.</p>
<p><span style="color: #333399;"><strong>How do I know if my project can qualify for the simpler prescriptive method?</strong></span></p>
<p>You can use prescriptive compliance if your project matches all of the features listed in Table 151-C of the Title 24 Residential Compliance Manual, which vary by climate zone according to the 16 climate zones of California. (The Bay Area is mostly Zones 3 or 4 with some 2 up north and 12 out towards Sacramento.)</p>
<p>The prescriptive baseline values used for most homes are also known as &#8220;Package D&#8221;.</p>
<p><span style="color: #333399;"><strong>What is Package D and where can I find the documentation?</strong></span></p>
<p>Package D appears to consist mainly of this one table, (Table 151-C) plus several pages of footnotes, which is tucked in the back of the Residential Compliance Manual under Appendix B. Even here not all the information is included; the table just says &#8220;MIN&#8221; for furnace AFUE for example.</p>
<p><span style="color: #333399;"><strong>What does the prescriptive method require?</strong></span></p>
<p>The following is a very simplified summary. For areas like San Francisco, East Bay and the Peninsula, wood-frame walls must be minimum R13, raised floors R19, and ceiling/roof R30. Glazing U factors must be .40 or lower, gas furnaces .78 AFUE or higher, and air conditioners must be SEER 13 or higher.</p>
<p>The prescriptive method places strict limits on the amount of glass that you can add, especially on the west. For additions from 100-1000 square feet, glazing must be less than 20% of the conditioned floor area &#8211; no curtain walls, sorry. If you have an addition that is under 100 square feet, that portion can&#8217;t have more than 50 square feet of glazing. If the project is an alteration and no area is being added, glazing can&#8217;t be more than 20% of the total conditioned floor area. Some climate zones also specify that only 5% of the total glazing area can be west facing.</p>
<div id="attachment_887" class="wp-caption alignnone" style="width: 360px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/medieval-ghent-castle-small.jpg" class="thickbox no_icon" rel="gallery-880" title="medieval-ghent-castle-small"><img class="size-full wp-image-887" title="medieval-ghent-castle-small" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/medieval-ghent-castle-small.jpg" alt="medieval ghent castle small Title 24 Compliance for Alterations and Remodels" width="350" height="233" /></a><p class="wp-caption-text">Medieval castles like this one had very low glazing-to-floor-area ratios.</p></div>
<p>So, if you want an addition with a glass curtain wall for your Esherick home, you will have to use the performance method.</p>
<p><span style="color: #333399;"><strong>I wasn&#8217;t planning on opening all the exterior walls. And I was going to reuse my old windows, too.</strong></span></p>
<p><em>Don&#8217;t count on being able to reuse the windows </em>unless they&#8217;re of fairly recent vintage. If your existing windows are single glazed, or clear glass instead of low-E, or they&#8217;re metal framed instead of wood or vinyl, you can forget it. All windows leak heat, but old ones leak a lot more. Keeping those old windows could easily double the energy budget for the entire home, which would kill your chances for Title 24 compliance.</p>
<p>For additions, alterations, or remodels, where only some walls, windows, or existing systems are upgraded, Title 24 allows several possible approaches or strategies. Again here, we&#8217;re talking mainly about the performance method, but these strategies are also available for the prescriptive method as well.</p>
<p>Obviously we can try modeling the project using the old windows, but we&#8217;ve ended up having to include a host of other measures to compensate &#8211; things like upgrading to a more efficient furnace, HERS-testing the ductwork for air leakage, even adding thermal mass.</p>
<p><span style="color: #333399;"><strong>What&#8217;s a HERS test?</strong></span></p>
<p>Most of you know this by now, but HERS tests are third-party field inspections for things like duct leakage, and you can earn &#8220;compliance credits&#8221; for these tests when using the performance method to show Title 24 compliance. Running the software model with one or more of these tests specified can improve the score of the proposed design, sometimes dramatically. They require additional coordination during construction, but are not as inconvenient as having to spend an extra $15,000 on new windows.</p>
<p>For more details, see our <a  href="http://greencomplianceplus.markenglisharchitects.com/interviews/inspections-title-24-compliance/" target="_blank">recent article on HERS inspections</a> and Title 24 compliance.</p>
<p><span style="color: #333399;"><strong>What&#8217;s the difference between modeling an Addition Alone or doing the remodel as a Whole House?</strong></span></p>
<p>Additions can be modeled as self-contained if conditioned square footage is being added, the new space is all in one spot, and for modeling purposes it&#8217;s best if the addition is at least partially sealed off from the rest of the house. As long as you insulate all those walls, including new interior walls, and use efficient windows,  you can model this additional space as its own self-contained little building. This means you can keep the crappy windows in the rest of the house.</p>
<div id="attachment_882" class="wp-caption alignnone" style="width: 310px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/addition-alone.jpg" class="thickbox no_icon" rel="gallery-880" title="addition-alone"><img class="size-full wp-image-882" title="addition-alone" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/addition-alone.jpg" alt="addition alone Title 24 Compliance for Alterations and Remodels" width="300" height="224" /></a><p class="wp-caption-text">This proposed addition adds square footage and uses new windows, while the rest of the house is left un-altered. This project could use Addition Alone compliance method.</p></div>
<p>However, if no square footage is actually being added, then you can&#8217;t show compliance for only one corner, even if that corner is getting the royal treatment. This can happen if, say, a family room is getting a facelift and new windows, maybe bigger windows than before, but it&#8217;s staying the same size as before. At this point you have to either meet the mandatory minimums for the altered portion, including maximum glazing-to-floor-area ratios that may apply to the entire building, or you have to use the performance method, meaning you have to model the entire project within one of those approved software programs mentioned earlier.</p>
<p>It also happens sometimes that the Addition won&#8217;t pass by itself. If we have to use the performance method because of glazing area or whatever, we can try running the addition by itself. However, sometimes even the most thoroughgoing modeling efforts will not yield a passing score. Then we have to model the entire building (or condo unit) &#8211; and for that, we need to include information on all the existing exterior surfaces: walls, roof, floor, and windows. If the existing conditions are unknown, we have to assume the worst, based on when the house was originally built.</p>
<div id="attachment_889" class="wp-caption alignnone" style="width: 310px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/whole-house.jpg" class="thickbox no_icon" rel="gallery-880" title="whole-house"><img class="size-full wp-image-889" title="whole-house" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/whole-house.jpg" alt="whole house Title 24 Compliance for Alterations and Remodels" width="300" height="264" /></a><p class="wp-caption-text">This proposed alteration is not adding new floor area. The main work is occurring towards the rear, including new windows and walls. However, there are also new skylights being added elsewhere in the house, and the front window is replaced with two new windows. This project would require the Whole House compliance method.</p></div>
<p><span style="color: #333399;"><strong>How does the Title 24 modeling software show a pass or fail score?</strong></span></p>
<p>What the software model does is compare energy usage of the proposed design (your remodeling plans) with the energy usage of that same house assuming the mandatory minimums. Model inputs include the home&#8217;s compass orientation, wall areas, floor areas, roof areas, glazing areas, actual systems in place, and performance numbers for each. For example, a 1,200 SF home oriented at 90 degrees east might have 270 SF of north facing exterior wall insulated anywhere from R0 to R25. This would be compared to a 1,200 SF east facing home with 270 SF of north facing exterior wall insulated to the minimum, R13. Your design has to beat this baseline, shown in this energy use summary as the &#8220;Standard Design&#8221;.</p>
<div id="attachment_884" class="wp-caption alignnone" style="width: 537px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/cf-1r-summary.jpg" class="thickbox no_icon" rel="gallery-880" title="cf-1r-summary"><img class="size-full wp-image-884" title="cf-1r-summary" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/cf-1r-summary.jpg" alt="cf 1r summary Title 24 Compliance for Alterations and Remodels" width="527" height="212" /></a><p class="wp-caption-text"> This sample Title 24 compliance report shows energy usage breakdowns separately for heating, cooling, and water heating. If the house is not passing, it&#39;s easier to see where improvements should be made first.</p></div>
<p><span style="color: #333399;"><strong>I really don&#8217;t want to open any more walls or replace more windows, because that will put us way over budget! My clients will go ballistic! Why can&#8217;t we just add more insulation to the parts that are being opened?<br />
</strong></span><br />
If you have to model the whole building, then all the existing conditions have to be modeled as they are now. This means that if any of the existing walls are un-insulated, that house is going to have a very hard time passing the software model, even if the rebuilt portions are insulated far beyond the minimum.</p>
<p>It is sometimes possible to use blown-in insulation for existing walls without having to open them completely. We have found that even minimal insulation of all walls is far better than leaving any portion of the walls at R0.</p>
<p><span style="color: #333399;"><strong>So it&#8217;s not passing, what do I do?</strong></span></p>
<p>At that point it&#8217;s a matter of incrementally testing in combination various additional measures that you may not have planned on doing. For example, if a house is ahead on heating but behind on cooling, then efficiency measures that aid cooling should be considered first. However, it&#8217;s also possible to achieve compliance through improvements to the heating system, even if the cooling is still below the minimum. That&#8217;s the advantage to using the performance method, and it&#8217;s sometimes the only way that highly glazed designs can pass.</p>
<p>If one measure isn&#8217;t available for a project, we can try others instead. Of course if there are too few alternatives &#8211; say they can&#8217;t afford to replace all the windows or they don&#8217;t want to get a newer, more efficient water heater &#8211; well, something still has to give. Resorting to elaborate workarounds in an effort to save money can introduce other risks into the project.</p>
<div id="attachment_886" class="wp-caption alignnone" style="width: 510px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/distraughtt.jpg" class="thickbox no_icon" rel="gallery-880" title="distraughtt"><img class="size-full wp-image-886" title="distraughtt" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/distraughtt.jpg" alt="distraughtt Title 24 Compliance for Alterations and Remodels" width="500" height="334" /></a><p class="wp-caption-text">Yes, we feel your pain, too, but you still have to replace those windows.</p></div>
<p><span style="color: #333399;"><strong>What additional measures should I be prepared to consider?</strong></span></p>
<p>Based on our own experience of 15 years doing Title 24 compliance for low-rise residential buildings, here are the findings that seem to hold true across projects.</p>
<p><span style="color: #800080;"><strong>Insulation.</strong></span> For remodels, do not leave any portion of wall un-insulated! This may not mean the entire house, unless we have to model it that way. Insulating to the maximum of what will fit inside the walls should be a given. This can include portions of the interior walls, too. (Radiant barriers are good in hot climate zones, but they don&#8217;t make much difference in San Francisco.)</p>
<p><span style="color: #800080;"><strong>HVAC.</strong></span> Upgrading heating, cooling, or water heating systems. This can be upsetting if the furnace is recent, but not quite recent enough. If your furnace has an AFUE of .90, but the project won&#8217;t pass unless that AFUE is .92, we have to deal with the situation as it is and find some way to address it.</p>
<div id="attachment_883" class="wp-caption alignnone" style="width: 550px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/additional-measures.jpg" class="thickbox no_icon" rel="gallery-880" title="additional-measures"><img class="size-full wp-image-883" title="additional-measures" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/additional-measures.jpg" alt="additional measures Title 24 Compliance for Alterations and Remodels" width="540" height="410" /></a><p class="wp-caption-text">For any remodel or addition project in California, additional measures may be required for Title 24 energy compliance. Clockwise from upper left: replacing inefficient windows, upgrading to more efficient heating/cooling/water heating systems, adding extra insulation, earning credits through HERS tests such as this blower door test, and finally, solar shading for homes that have problems with summer solar heat gain.</p></div>
<p><span style="color: #800080;"><strong>Windows. </strong></span>Replacing all or most of the existing windows. Obviously this can get expensive, and we try to avoid this. On one project we had to specify every HERS test there was, because they wanted to keep 5 existing windows that were metal-framed with clear glass. This project also had existing window that were wood framed with clear glass, but it was the metal ones that hurt the project the most. Poor window performance is the Achilles heel of compliance.</p>
<p><span style="color: #800080;"><strong>HERS verifications.</strong></span> We used to discourage the use of these third-party tests because it&#8217;s cumbersome to have to coordinate for yet another inspection during construction. And, there&#8217;s no guarantee that the test will pass on the first try, although there are ways to prepare for them to help things go smoothly. Now we&#8217;ve had to resort to them for about half our Title 24 projects.</p>
<p><span style="color: #800080;"><strong>Design changes.</strong></span> Our whole raison d&#8217;etre is to help architects comply with Title 24 without having to alter the design in a visible way. No shrinking of windows, no adding of south wall overhangs if the original design didn&#8217;t call for them. We&#8217;ll recommend product substitutions, but we&#8217;ve never had to tell someone that they couldn&#8217;t have their all-glass panoramic view. Still, I&#8217;m sure someday we&#8217;ll get a project where adding an overhang or side shading wall makes that 0.01% bit of difference between passing and failing.</p>
<div id="attachment_888" class="wp-caption alignnone" style="width: 339px"><a  href="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/thermal-image-clear-vs-solarban.jpg" class="thickbox no_icon" rel="gallery-880" title="thermal-image-clear-vs-solarban"><img class="size-full wp-image-888" title="thermal-image-clear-vs-solarban" src="http://greencomplianceplus.markenglisharchitects.com.s3.amazonaws.com/wpb/wp-content/uploads/2010/08/thermal-image-clear-vs-solarban.jpg" alt="thermal image clear vs solarban Title 24 Compliance for Alterations and Remodels" width="329" height="300" /></a><p class="wp-caption-text">Windows can leak heat in cold weather, but they also can admit too much solar heat gain on hot, sunny days, as shown in this illustration. The window on the left would be associated with higher cooling loads.</p></div>
<p><span style="color: #333399;"><strong>How accurate is the Title 24 software model? Just because a measure doesn&#8217;t help in the model, does that mean it&#8217;s really worthless?</strong></span></p>
<p>Absolutely not! The Title 24 modeling software calculations are actually pretty thorough, although there are some intentional omissions that can, at times, make the building&#8217;s real-world performance quite different from what the model would predict. A home that in reality is covered by shade trees and a nearby mountain may show unrealistically high cooling loads in Title 24, because shade trees, adjacent buildings, and landforms are specifically not allowed as factors for compliance. I&#8217;m not going to get into the reasoning, but that&#8217;s how it is. Title 24 errs on the side of conservatism, so a house that does well in Title 24 should also do well in reality, even if the reverse is not always true.</p>
<p>What it&#8217;s good for is comparing the relative impact of one change over another. You can test the sensitivities of using triple glazed vs double glazed windows on just the west or south walls, for example, to see where you can get the most bang for the buck.</p>
<p>I don&#8217;t think the Title 24 software models are quite accurate enough to create energy budgets for things like Net Zero Energy homes, or to model temperature flows for passive solar designs. For one thing, appliances like TVs and computers aren&#8217;t considered at all, nor are differences in occupant behavior. It could give a rough cut analysis of major opportunities for optimizing the design, but then you&#8217;d have to move to something else.</p>
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		<title>What Do HERS Raters Do?</title>
		<link>http://greencomplianceplus.markenglisharchitects.com/discussions/project-management/raters/?utm_source=rss&#038;utm_medium=rss&#038;utm_campaign=raters</link>
		<comments>http://greencomplianceplus.markenglisharchitects.com/discussions/project-management/raters/#comments</comments>
		<pubDate>Wed, 27 May 2009 20:20:06 +0000</pubDate>
		<dc:creator>Alan Huguenot, CEPE</dc:creator>
				<category><![CDATA[Project Management]]></category>
		<category><![CDATA[HERS]]></category>

		<guid isPermaLink="false">http://greencomplianceplus.markenglisharchitects.com/?p=279</guid>
		<description><![CDATA[HERS raters evaluate onsite installation techniques, take key measurements,  perform inspections and duct testing procedures to verify a home’s energy efficient performance, and then electronically file with the appropriate agencies.]]></description>
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			<a  href="http://api.tweetmeme.com/share?url=http%3A%2F%2Fgreencomplianceplus.markenglisharchitects.com%2Fdiscussions%2Fproject-management%2Fraters%2F"><br />
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<p>As registered and certified Home Energy Raters, we are trained by our HERS Provider (CalCERTS) to evaluate onsite installation techniques, take key measurements,  perform inspections and duct testing procedures to verify a home’s energy efficient performance, and then electronically file with our HERS provider (CalCERTS) the Title 24 forms which verify that a new home matches the CF-1R created by the Title 24 Author.</p>
<p><span id="more-279"></span><strong><br />
</strong></p>
<p><strong>Completion of Field Verification.</strong> As HERS-Raters we conduct on-site Third Party Field Verification and diagnostic testing of the completed construction and then fills out the Title 24, CF-4R Certificate of Field Verification and Diagnostic Testing, This field verification ensures that energy-saving measures are consistent with the chosen performance guidelines as specified in the CF-1R issued by the Title 24 Documentation Author. As the  HERS-Rater we follow the inspection protocols and testing guidelines of our Provider (CalCERTS). The full testing process may include a blower door test (to test the leakiness of the houses thermal envelope), a duct blaster test (to test the leakiness of the duct system), and even a smoke test to locate the duct leaks. This may be followed with completion of a thermal bypass checklist (a visual inspection of common construction areas where air can flow through or around insulation</p>
<p><strong>Forms Processing:</strong> As the HERS-Rater we then process the CF-4R and CF-6R forms electronically through our HERS Provider (CalCERTS) who administers a State-approved rating system and maintains the completed Title 24 forms electronically. The local Building Department Official will require the CF-6R form to finalize the Building Permit, and provide a Certificate of Occupancy. Also the Building Department Official may require a copy of the CF-4R to be filed with the final permit sign-off.</p>
<p><strong>Energy Star for Homes &amp; GreenPoint Rating:</strong> Finally, if the local jurisdiction utilizes GreenPoint ratings in their residential energy code, as most of the jurisdictions in Bay area and Northern California are beginning to do. Then as your HERS-Rater we will also verify the homes GreenPoint rating in accordance with Build-It-Green’s GreenPoint checklist. If the homeowner wants to achieve EPA’s Energy Star for homes ratings, then as HERS-Rater we can also provide that, as well as verifications for the various Tax Incentive programs which have been created to stimulate Energy Efficiency.</p>
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		<title>What Do Energy Analysts Do?</title>
		<link>http://greencomplianceplus.markenglisharchitects.com/discussions/project-management/energy-analysts/?utm_source=rss&#038;utm_medium=rss&#038;utm_campaign=energy-analysts</link>
		<comments>http://greencomplianceplus.markenglisharchitects.com/discussions/project-management/energy-analysts/#comments</comments>
		<pubDate>Tue, 26 May 2009 19:10:10 +0000</pubDate>
		<dc:creator>Alan Huguenot, CEPE</dc:creator>
				<category><![CDATA[Project Management]]></category>
		<category><![CDATA[CEA]]></category>
		<category><![CDATA[ECM]]></category>
		<category><![CDATA[Home Energy Audit]]></category>

		<guid isPermaLink="false">http://greencomplianceplus.markenglisharchitects.com/?p=276</guid>
		<description><![CDATA[Certified Energy Analysts can provide Existing Home Energy Audits, Selection of Energy-Efficiency Measures, and New Homes Title 24 Documentation and Modeling.]]></description>
			<content:encoded><![CDATA[<div class="tweetmeme_button" style="float: right; margin: 3px 0 0 3px;">
			<a  href="http://api.tweetmeme.com/share?url=http%3A%2F%2Fgreencomplianceplus.markenglisharchitects.com%2Fdiscussions%2Fproject-management%2Fenergy-analysts%2F"><br />
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<p>Registered California Certified Energy Analysts (CEA’s) such as ourselves can assist Architects, Builders and Developers through:</p>
<p><strong>Existing Home Energy Audits:</strong> The Certified Energy Analyst (CEA) performs a site survey of an existing home and identifies all energy consuming equipment; Lighting, HVAC and Appliances. The CEA also measures the home and determines R-values and U-values for the existing building envelope. Performing a general ducting and systems visual inspection, looking at hot water tank blankets and insulation, hot water re-circ systems etc. The CEA may also decide that a duct blower test or door blower test, usually done by a HERS-rater may be required to determine the tightness of the building and ducting leakage.<br />
<span id="more-276"></span><strong>Selection of Energy-Efficiency Measures (ECM’s) and Certifications</strong>:  The CEA then identifies appropriate ECM’s by simulating the home’s energy usage with a Title 24 Energy Efficiency Modeling program. The results of this analysis allow the CEA to select the most effective upgrades to meet the intended certification of Title 24, Energy Star, Green Point Ratings, LEED for Neighborhoods, Federal Tax Credits or New Solar Homes Partnerships, within the specific performance guidelines.</p>
<p><strong>New Homes Title 24 Documentation &amp; Modeling:</strong> California Certified Energy Analysts (CEA’s) serve as Title 24 Documentation Authors for Architects, Builders and Developers, by providing the official forms documenting the INTENDED (CF-1R), INSTALLED (CF-6R),  and  the VERIFIED &amp;TESTED SYSTEMS (CF-4R).<br />
<strong>Note: </strong><em>Some California jurisdictions (for example Stockton) are now requiring that any permit applications requiring Title 24 documentation, must be authored by a CABEC-certified CEPE or CEA.</em></p>
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		<title>Title 24 and HERS: The Only Two Key Project Roles</title>
		<link>http://greencomplianceplus.markenglisharchitects.com/discussions/shameless-self-promotion/title-24-two-key-project-roles/?utm_source=rss&#038;utm_medium=rss&#038;utm_campaign=title-24-two-key-project-roles</link>
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		<pubDate>Mon, 25 May 2009 17:28:29 +0000</pubDate>
		<dc:creator>Alan Huguenot, CEPE</dc:creator>
				<category><![CDATA[Project Management]]></category>
		<category><![CDATA[Shameless Self-Promotion]]></category>
		<category><![CDATA[HERS]]></category>
		<category><![CDATA[roles]]></category>

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		<description><![CDATA[The underlying truth is that, on any project there are actually only (2) players that make any difference where energy is concerned; the Title 24 Documents Author, and the HERS Rater. These are the guys with the official sanctions from the State of California to actually file the necessary paperwork.]]></description>
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<p>We often get asked, “Who does what with Energy Compliance?” with regard to new residential construction and existing residential remodels. The traditional roles of Architect, Building Contractor, and Sub Contractors are well understood. But, as energy efficiency has become more regulated and the documentation required by the California Energy Efficiency Code (Title 24) has become more complicated&#8230;</p>
<p><span id="more-274"></span>&#8230; there has been a parallel proliferation of various Energy Experts and different Energy Raters each claiming to be the Real Green Expert. This seeming power vacuum has spawned a plethora of organizations competing for market share and each claiming to be the True Green Authority, some with governmental sanctions, but many without any official charter what-so-ever.</p>
<p style="text-align: left;">Unfortunately, in this free market we now have: BUILD-IT-GREEN, the CEC, CalCERTS, CBPCA, CHEERS, CABEC, CSLB, CARB, CEE, CPUC, CHPS, CalSEIA, DSIRE, EPA, Energy Star, EERE, IREC, LBNL, NCSEA, NREL, REPP, ResNET, SBIC, and finally in last place for residential and definitely not LEED…ing the pack is the USGBC, with LEED for Neighborhoods. Yet, this alphabet soup does not even include the public utilities which also have their own proliferation of sub-agencies….. So you might well be left asking, “Who are all these people?&#8230;.. The short answer is….</p>
<p><strong>“At Green Compliance Plus® we strive to be all of those people for you”.</strong></p>
<p>The underlying truth hidden beneath the green chaos is that, on any project there are actually only (2) players that make any difference where energy is concerned; the <strong>Title 24 Documents Author</strong> (a CEPE or CEA certified by CABEC), and the <strong>HERS-Rater</strong> (certified by CalCERTS, CBPCA, or CHEERS). These are the guys with the official sanctions from the State of California to actually file the necessary paperwork.</p>
<p>Here at Green Compliance Plus® we are certified and licensed by California to do both halves of the Energy Analysis and Verifications for you. In my next post I&#8217;ll explain what Energy Analysts and HERS Raters do.</p>
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