“People don’t understand the impact of ‘beyond compliance’ and what it requires,” said Mark English, as we were discussing Title 24 energy compliance for various types of custom home designs and remodels. “They don’t understand the difficulty of getting even very small additions to comply – and if they have to meet local green building ordinances that require exceeding Title 24 by 15% or more, it’s even more challenging.”

The problem with additions is that you have less to work with if the project doesn’t comply. Small additions are the hardest, and alterations are even worse, because you’re not adding any conditioned area. If it doesn’t qualify for prescriptive (simple but rigid), you have no choice but to do a whole house energy model. And with the energy model method, you have to justify the values used for the rest of the house that’s not being touched, and which may be built to a long-obsolete energy standard. Those existing R-0 walls can cost you.

Local Green Building Requirements Can Differ

Local green building ordinances can vary in very unpredictable ways. Some areas are adopting BuildItGreen’s GreenPoint Rated system, which at a minimum requires 15% over compliance for new construction. That alone means an energy model, since you can’t “exceed” compliance using the prescriptive form. With the simpler prescriptive form it’s very black and white: either you meet every requirement, or you don’t comply – there’s no extra credit in one area to make up for shortfalls in another.

And it’s not just the GreenPoint checklist that the jurisdictions want, either. If a local Building department is using the GreenPoint Rated system, they often want to see the full follow-through, with a third-party rater who checks up on the project all the way through construction. Others are adopting CALGreen optional tiers, which have pretty much the same measures as BuildItGreen, but it’s structured differently – and that can also have an impact. A locality can even adopt a green building ordinance all on its own that doesn’t reference these systems, although that’s less likely than choosing one standard and then piggybacking further requirements on top of it.

For example, Portola Valley has added a sliding scale GreenPoint score where the larger the house, the more GreenPoints it needs. One of our recent Title 24 projects, a new 6,000 square foot house with 40% glazing to floor area, and metal framed windows (less efficient) required 172 GreenPoints, and in order to make that, we needed to get that house to exceed Title 24 by 35%!

At least with that project, we had the whole house design to work with. We got that project early in the design phase, so we could work with the architect to specify better windows, test out the impact of various system efficiencies, and discuss the additional credits of HERS testing with the assurance that it would likely pass all those tests. With additions, you have to perform the same miracles without altering the majority of the building. And you never know what a local green building ordinance may require.

Even Interior Remodels Now Require Title 24 – in Burlingame

Here’s an example that just came up, and is the subject of this case study. One of our recent Title 24 projects, a remodel of a private home in Burlingame, CA, was mainly an interior remodel. Who knew that Burlingame has an expenditure threshold where any construction project costing over $50K now triggers a Title 24 compliance requirement that has to beat the standard by 15%? And a GreenPoint Checklist with a minimum of 50 points? It’s not like they’re even changing the building envelope.

Well, Mark ran this project and it was -174% behind. “It simply couldn’t be done,” he told me. “It was a nice Mid-Century Modern home with lots of glass everywhere, and vintage insulation. Even if we replaced every window and the heating system, we wouldn’t even make the baseline, let alone 15% over.”

The home's existing condition, before the interior remodel which had no impact on the exterior envelope whatsoever, failed Title 24 by an impossible margin. Note that California's energy code assumes a minimum 13 SEER cooling system, whether any cooling is installed or not.

Mark spoke to a Burlingame city Green Building official, who bluntly told him, “You can apply for a hardship exemption, but you’re not likely to get it.” The owner, a medical professional whom we’ll call Dr X, was already committed to making this project happen. This would have crushed the project completely – and for no justifiable reason.

Then, Mark had a brainstorm. He talked the owner into replacing the heating system with top-of-the-line efficient equipment, and then he created two separate reports: a “before” and an “after”. The “after” report was only (only!) -120% under, a 50% improvement! The home didn’t have any cooling system installed, so no help there. Title 24 assumes you have one even if you don’t, and penalizes accordingly.

The owner agreed to upgrade his heating system and got a 50% improvement.

A Happy Outcome

The owner then submitted the two reports to the City, along with a hardship application form – and to everyone’s astonishment, he got his permit. He wrote us a lovely handwritten note:

“Dear Mark,

Many thanks for all your work and suggestions. I turned in your Title 24 analysis and the hardship for with your wording plus additional palaver and got the permit Monday. It would have been a bleak Thanksgiving if I was still in a suspended state. I really appreciate everything you did.

Best,

Dr. X.”

Lessons Learned

What are the lessons to be learned from this exercise, aside from the fact that new regulations can have unanticipated consequences? Here is what we concluded:

1. Don’t assume that additions are easier than whole-house remodels. You have a lot less to work with and fewer opportunities to improve performance.
2. It’s very hard to get an addition to comply on its own.

Be told.

Impact of Poorly Designed Regulations Can Be Catastrophic

Mark English, ever the advocate for both architects and homeowners, put it this way. “You can’t inhibit people from upgrading their homes – it only kills the economy and prevents construction from happening at all. You can’t hold people hostage and force them to rebuild their entire house for some ridiculous bureaucratic rule that no one’s thought through. At the very least, Burlingame should raise that construction threshold to something like $200K, because any interior remodel, even a kitchen and master suite, can easily cost $125K and more – without any changes to the envelope.”

This goes back to one of our earlier articles on QII credits for spray foam – another “gotcha” that almost cost one of our Title 24 projects its compliance in the field – too late in the game to make it up easily through design or construction changes. The way regulatory processes work, the people writing these codes can’t anticipate their impact in the field, unless we bring it to their attention. I sure hope they see this article!

This news flash about a seemingly obscure topic is of immediate importance to all our architect Title 24 clients -and it’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’ve had a couple of nasty surprises with it in the past.

Apparently, up until around yesterday, the California Energy Commission did not officially recognize the QII test as valid for open-cell spray foam. Our insulation expert James Morshead of SDI Insulation actually sent me an urgent email yesterday with the news, saying:

Today the California Energy Commission stepped out of the 1980′s and into the 1990′s! The 1/2 pound density spray foam QII check list has finally been approved after long delays.

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.

Now on to fixing the U-Value tables!

Active lobbying at the CEC is necessary

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’s  inner working processes. Most of us don’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.

A QII teaching case with the New Solar Homes rebate

We’ve run into some issues on the QII test before, where we’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 – NOT one of our Green Compliance Plus Affiliates – 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’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’s energy compliance documentation – and the NSHP rebate. There was much tearing of hair and gnashing of teeth all around.

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.

Whys’ this QII change so darned important?

What are the ramifications of this change and how did it come about? “The recognition of open-cell spray foam has been in process for six and a half years,” said James. “We at SDI didn’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’re not set up to do that. They’re set up to be reactive, influenced by lobbying input from stakeholders in the marketplace.”

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. “That’s normal business. The CEC is a government agency, and that means that they’re encumbered themselves by a lot of regulatory process. They’re restricted by the system themselves. They rely on input from competing parties, and they solicit information by saying, ‘We want your input.’ They rely on the stakeholders to approach them and provide the necessary technical information.”

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. “They’re coming from an analytical and academic standpoint, but they’re NOT in the field.” And that’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’t believe it worked AT ALL. “They were writing regulations without ever having seen it in action.”

James went on to emphasize that he didn’t fault anyone at the CEC, in fact he admired their work and didn’t envy their task. They’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’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’t go into effect until 2010. And, some of its provisions weren’t enforced across the board until October of 2011.

Meritage Homes – a study in foam

Then we got on the topic of Meritage Homes, a high-end home developer who was apparently instrumental in adopting and demonstrating the real value of spray foam. Meritage’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’t selling, because of the economy of course – not because the homes were bad. Nobody was buying anything, no one could get financing.

“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!”

Meritage Homes is a high-end home development company that has implemented energy efficient building envelopes as part of the core design.

And that’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’s Joint Appendices might disallow the use of its true performance capabilities when doing home energy calculations. Which isn’t really fair, considering how difficult it’s been to get even ordinary home designs to meet current California energy standards.

The deconstructed home as sales tool

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’s built. But Meritage did something different. They had a model home with cutout walls to show the interior building assemblies, including studs, wiring – and spray foam insulation. “I call it the deconstructed home,” said James.  “People now are smarter, more educated about building and energy efficiency. They want to see what’s inside. And sales took off! It was a totally new way to sell houses. Local building inspectors liked it, too.”

The homes weren’t selling for more money, but they were selling a lot faster – and, to investors, time is money. The quicker you can recover an investment, the less financing costs you have.

By showing a "deconstructed home" 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.

CEC’s focus on new construction ignores issues for remodels

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 – I haven’t yet found any data specifically comparing either dollars spent or number of projects of each type, in CA).

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’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’t qualify for prescriptive compliance. And let’s say that this is a low-budget project; they’re changing out the heating system and enlarging a couple of windows and leaving the rest alone, maybe it’s mainly an interior remodel which doesn’t affect the building envelope.

Well, there are times we’ve had to run a whole-building model that included all portions of the existing home that aren’t being upgraded, but which aren’t built to current energy standards. It’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 “sustainable building”? I’ve spent hours reading the Residential Compliance Manual’s sections on alterations and remodels, and sometimes writing to the CEC, to find out what’s really allowable.

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 "The Circus, 1870-1950" published by TASCHEN.

QII checklists for each type of insulation didn’t include one for open-cell spray foam

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’s one QII checklist for fiberglass batt insulation, and a different checklist to use for blown-in, etc. Here’s a nice checklist writeup from ConSol, an energy group based in Stockton.

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’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’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.

Some HERS raters have very extensive backgrounds in building efficiency, construction, and green building; others just don’t have the same depth of knowledge. That’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, “Well, you fail, and there’s nothing I can do to help. You won’t get your rebate after all. ‘Bye, now.”

The CEC doesn’t always realize these ramifications until they’re pointed out

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, “This product doesn’t work. Therefore, it’s not allowed.” What he really should have said was, “This product doesn’t have an authorized CEC checklist. And it’s still not allowed.”

Checks and balances to prevent cheating are well intentioned, but they can really gum up the works

“The CEC really wants to discourage cheating,” said James. There are certainly more steps to verification now than in the 2005 code. The whole CalCERTS registry process, 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’ve never had to consider a different workflow for custom homes where an architect is directly involved.

The code update process is complex and unforgiving, not unlike San Francisco’s planning and approvals process.

So – what if someone wants to advocate for, say, a better attention to remodels, or to custom architect-designed homes? You’d better have a full-time staff person on the job. “The process is so cumbersome, with hearings, submittals, and a lot of 45-day language,” said James. (Really it’s just like the SF planning process) “It’s really arcane – miss something and you’re dead.”

Other industries have their own issues to push for in the energy code. “HVAC, energy consultants, builders… there are a few people who practically sleep in their cars down at the SMUD building in Sacramento.”

It helps to establish a good rapport with the CEC staff, who got high marks from James for dedication and responsiveness. “If you know the system really well, you can know which events are important, but you can’t tell just by looking at the CEC site. It’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.”

Is the Net Zero goal realistic and achievable by 2030?

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. “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 – air sealing, HVAC sizing, more credit for unventilated roof assemblies.”

“Net Zero Energy is a great idea,” he continued. “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’t ready. NZE is such a complex concept, it requires a very integrated approach. If you push it on people too fast, it’ll be a disaster in the implementation.”

I can’t argue with him there.

As most of our readers now know, California’s energy code got a lot stricter in January of 2010. Increasingly, HERS tests are required to comply, even for custom residential projects. HERS tests are special third-party field inspections for things like ductwork, insulation, and air-conditioner efficiency. These tests are called out on the Title 24 energy compliance report, also known as the CF-1R. This energy report must be included on all Building Department submittals statewide throughout California to obtain a building permit. The energy report is then reviewed as part of the plan check process.

And now, a new requirement, or really an old one that’s just now being enforced: All CF-1R reports that call for a HERS test must be officially “registered”. Don’t say we didn’t warn you. Plan checkers are starting to kick back custom residential submittals if they don’t see a CalCERTS watermark on the energy report.

But first, a little background.

Our clients are other design-oriented (read: “modern”) architects. Some of them like to use dramatic walls of glazing in their designs. This, while awesome, presents an energy problem, because glass is a poor insulator compared to, say, a 2×6 framed wall cavity packed with high-performing insulation. California’s energy code seeks to discourage over-glazing by imposing a maximum glazing threshold at 20% of the conditioned floor area.

The Title 24 prescriptive energy report, showing where various HERS tests can be called out. This example is the CF-1R-ADD form for Additions. Title 24 is a reference to California's energy code.

The only way around this is to employ a complex “performance approach” to energy compliance, whereby the project is run through energy modeling software that allows trade-offs – acres of picture windows in exchange for beyond-code energy upgrades elsewhere. As long as the house as a whole is under the threshold for energy usage, the designer can creatively determine how that goal is achieved.

For the performance method of Title 24 energy compliance, the energy modeling software shows whether HERS tests are required on the report's summary page. This example output is from Micropas, a software package that is one of only two authorized packages for demonstrating California energy compliance. As you can see, the project is barely passing even with the additional HERS credit.

For Those Who Came In Late

What are HERS tests?

HERS stands for Home Energy Rating System, a method of diagnostic analysis to determine a home’s energy efficiency by establishing a benchmark and then making site-specific upgrade recommendations for the homeowner. It’s not specific to California; other state energy codes sometimes reference HERS as a standard or its later incarnation, HERS II. HERS raters are independent contractors who are trained and certified through an organization such as CalCERTS.

Why does California’s energy code include HERS testing?

HERS is a recognized and proven standard that relies on empirical testing on a case-by-case basis. Many of the HERS tests address well-known construction deficiencies that can waste up to 30% of a home’s total energy consumption. With a goal of having all new homes statewide be Net Zero by 2030, the State of California has employed a phased approach that tightens the energy code in three-year increments.

When does California require HERS testing?

Depends which energy compliance method you use. Prescriptive requires certain tests, like the duct blaster test, for any new construction or any time a forced-air system is replaced. Performance has this as an option, because it boosts the score quite substantially.

What is this magic database up in the sky, and why haven’t I heard of it before?

Actually, you have if you’ve been reading our blog. But, if you read our blog, chances are your’e the last group of architects to be affected by it. Back in 2009 I took a CABEC-sponsored Title 24 class in Sacramento on upcoming code chances. However, at that time nothing had been implemented, and no one knew how it would actually work.

Since then, CalCERTS has been working with the California Energy Commission to get this up and running. It’s been gradually phased in for different types of projects: mainly production homes, which are far more numerous than the custom, one-off projects and remodels that comprise our own design focus.

The CalCERTS online registry tracks the CF-1R energy compliance reports that require HERS testing. This example is for a residential project.

As an aside, I found the CalCERTS online registry to be very fast, with no glitches – the test project I did in order to write up this article worked just fine. The registry actually parses the report file (a special un-readable ZIP file generated by the energy modeling software) so it “knows” what the project requirements are. The CalCERTS folks themselves were very courteous, helpful, and responsive. I was very impressed that the entire online interface was implemented by one person, who seems to have taken every last aspect of the energy compliance process into account. There oughta be a medal for that!

Why do we need a database? Isn’t there enough red tape as it is?

The idea behind the registry is to reduce cheating. Prior to this, any CF-1R requiring a HERS test had no follow-up to ensure that the test was actually performed, or that the project actually passed the test.

To discourage cheating, CalCERTS registry requires a special output file. It then creates a readable PDF file with the CalCERTS "watermark" applied behind. It also adds a footer to the report with a registration number. This example shows how the watermark is applied to an energy performance report.

So, Who Does What?

Here’s a magic molecule diagram that shows the “new” process highlighted.

Custom residential projects that require HERS testing must now register online with CalCERTS to show compliance with California's energy code.

Green Compliance Plus clients: We take care of pretty much everything that’s in the shaded box. The only thing you’ll need to do is make sure that if your Title 24 energy report calls for any HERS tests, you’ll need the watermarked version on your submittal package.

Note that this diagram only goes up to permitting – there’s a Part II that shows how all the installation certificates and HERS test results are uploaded later down the road. For now, suffice it to say that whatever’s in that energy report has to be followed in the field, because if something doesn’t match up, chances are either the HERS rater or the building inspector will pick up on it.

Impact of Design Changes and Field Swaps

All this bureaucracy means that any changes to the design, including field swaps, could mean having to re-do the energy compliance report and a whole slew of headaches for architect, builder, and owner alike. The energy-modeling “performance” method that we use most of the time allows you to specify the exact efficiencies of every piece of heating equipment and every single window. This allows for a lot of flexibility but it also locks you in to using products that meet those numbers – and are field labeled as such.

Here are just a few of the changes that could trigger a new round of energy analysis: changes to unit models for heating, cooling, or water heating equipment, especially efficiency; any change to the building envelope, including wall and roof assemblies; moving to a less efficient window product; failing a required HERS test; local building requirements that mandate exceeding Title 24 by a specified percentage.

Re-doing the energy report means you try to make up the shortfall somewhere else. This gets harder to do the further along the project is in construction. If you get caught during a site inspection, the damage control can eat up the project budget, not to mention irritating YOUR clients – the homeowners who rely on you, the architect, to guide the project smoothly to completion.

Don’t paint yourself into a corner. Make sure that your builder and all the builder’s subs REALLY understand what’s on that energy report.

All This Applies to Remodels, Too

Even alterations, additions, and other remodeling efforts within the State of California may be subject to this CalCERTS registry requirement. Oftentimes, these are our toughest energy compliance projects, because the scope is limited but for one reason or another we can’t use the simpler prescriptive approach. Usually it’s because the project is over the glazing limit. However, we don’t have much room for energy trade-offs using the energy model because most of the house isn’t being opened or altered.

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

To complete California's New Solar Homes Partnership process, you will need a solar company, a Title 24 consultant who's also a Certified Energy Plans Examiner (CEPE), and a HERS rater.

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.

1. The home must get service from PG&E. If needed, fill out an application for new service for the selected location.
2. You’ll also need to fill out another PG&E application for Net Energy Metering.
3. 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.
4. Get your Title 24 report (the CF-1R) done by a Certified Energy Plans Examiner (CEPE) using the performance method.
5. Price out your solar system to a vendor whose name and address are registered with the CEC.
6. 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.

Construction phase

• 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

Post construction

• 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.

New Solar Homes Partnership process part 1 of 2. This includes the new forms from the California Title 24 2008 energy code, which went into effect in 2010.

California New Solar Homes Partnership process part 2 of 2

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.

======= wait =====

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.

==== final stuff ====

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.

Client Experiences

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
    
  • Appliances
    
  • Solar equipment
  • Glazing products
    

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.

I know we’ve published several of these, but this is updated to show more specifics. These are the requirements that will be in effect when the new 2008 Title 24 goes “live” in January 2010.

These requirements reference two compliance methods, a prescriptive method and a performance method. The prescriptive method is simpler but offers less flexibility, whereas the performance method uses a software modeling program with a detailed series of inputs that can be modified to test various trade-offs. We at Green Compliance Plus use the performance method.

FENESTRATION: The compliance model standard design (the hypothetical building that your design has to meet or beat) has been upgraded such that the fenestration has to have a U-factor of 0.40 for all climate zones except Climate Zone 15, where it has been reduced to 0.35. All fenestration will be required to have both permanent and temporary labels.

ELECTRONIC DOCUMENT FILING: All CF-1R, CF-6R and CF-4R documentation must now be filed online with a HERS Service Provider.

NEW STATE OVERSIGHT REQUIREMENTS: The state will be using these electronic filings to check on building department inspectors.

COOL ROOF SOLAR REFLECTANCE INDEX (SRI): This new measure of a surface’s reflecting ability has been added to the code, along with new requirements for low-sloped and steep-sloped roofs. A steep slope is greater than 2:12 or 9.5 degrees.

NEW COMPLIANCE OPTION CREDITS FOR:

• Zoned heating controls, when using the performance method for Title 24 calculation.
• Distributed energy storage
• Evaporatively cooled condensers
• Evaporative coolers
• Controlled ventilation crawl space
• Cooling coil air flows that exceed prescriptive requirements
• Fan watt draws that are leass than the prescriptive requirement of 0.58 watts per CFM
• Low leakage air ducts in conditioned spaces
• Solar water heating can be used as a trade-off when using the performance method.

Blown in insulation is one way to make existing homes more efficient

NEW REQUIREMENTS FOR:

• Building Envelope: There are several revisions to the mandatory requirements for insulation and roofing.
• Mechanical Ventilation: These are Indoor Air Quality requirements which generally follow ASHRAE <http://www.ashrae.org/> Guideline 62.2. All low-rise residential construction will be required to have a whole-house ventilation system. Operable windows are not an approved ventilation system. The system shall have MERV 6 or better filtration system.
• Forced-Air Systems: There are new prescriptive requirements for forced-air systems. Fan watt draw limitations (no more than 0.8 watts per CFM) and minimum air flow rates for ventilation have been added to the new code.
• Calculation of Heating and Cooling Loads: Heating and cooling loads must be fully calculated even when using the Prescriptive Method. This is already done in the performance method.
• Spas & Pools: Time clocks and two flow speeds will be required on all spa pumps in order to limit flow velocity.
• Refrigerant Charge: When using the prescriptive method, it will be almost impossible to avoid a HERS verification of the refrigerant charge if you provide any form of air-conditioning. If you install a split system, it must be verified by a HERS rater.
• Hot Water Piping: Under-slab insulation of hot water piping will be required.
• Refrigerant charge measurement is now a prescriptive requirement in Climate Zones 2 and 8-15.
• Lighting Controls: New mandatory requirements for lighting controls.

NEW ALLOWANCES FOR:

• Metal Frame Walls: Metal frame wall assemblies can be used, if the spray-on polyurethane foam is verified by a HERS rater before the sheet rock is put on.
• Existing Wood-Framed Walls: Existing R-11 wood framed walls need not comply with R-13, if performance method is used.
• Solar water heating can be used as a trade-off when using the performance method.

Still have questions on Title 24? Visit the Title 24 home page on the California Energy Commission’s web site.

The 2008 Title 24 requirements, which will become effective in January of 2010, will now require both HERS verification and electronic document filing and registration for all Title 24 documents, including the following:

• The CF-1R Certificate of Compliance, which completed and signed by both the Title 24 Document Author and the Architect
• The CF-6R Installation Certificate, completed by the installing contractor
• The CF-4R Certificate of Field Verification and Diagnostic Testing, completed by the HERS Rater

Any time any of the following HERS verifications are required, all these documents will now have to be registered and filed online with a HERS Provider who is certified through CalCERTS, CHEERS, or CBPCA. This means that, starting in 2010, designing architects will need to work with a HERS provider. As certified HERS raters through CalCERTS, we can verify the following:

• Duct sealing (duct blaster test)
• Supply duct location, surface area and R-value
• Low leakage for ducts in conditioned spaces
• Low leakage for air handling systems
• Verify refrigerant charge in split system air conditioners with heat pumps
• Cooling coil airflow
• Air handler fan watt draw
• High energy efficiency ratio (High EER)
• Maximum rated total cooling capacity
• Evaporatively cooled condensers
• Ice storage air conditioners
• Building envelope sealing (door blower test)
• High-quality insulation installation
• Photovoltaic field verification protocol

A HERS rater can verify that insulation is properly installed

It has become obvious that, on any project there are two players that make or break a project where energy is concerned:

• The first is the Title 24 Documentation Author. This is the person who creates the inputs and runs the Title 24 performance calculation model and writes up the Title 24 documents. In some jurisdictions, it is mandatory that Title 24 documents be completed by a Certified Energy Plans Examiner (CEPE) or Certified Energy Analyst (CEA) certified by CABEC. By an astonishing coincidence, we happen to have those qualifications as well.
• The second player is the HERS Rater, who must be certified by CalCERTS, CBPCA, or CHEERS. The HERS rater verifies the installation of energy-efficient measures and materials, and runs the diagnostic tests that are necessary to verify that the installation agrees with the Title 24 compliance calculations.

Both of these people have official sanctions and certifications from the State of California to actually file the necessary paperwork.

Here at Green Compliance Plus® we are certified and licensed by California to do both the Energy Analysis (Title 24 calculations) and the HERS Verification and diagnostic testing for you. We can also take care of the electronic filing requirements.

Those of you with T24s in process or coming up soon might like to know that the California Energy Commission has pushed back the Title 24 2008 rollout to January of 2010. We’ve been telling all our Title 24 clients to get their designs in before August 1, but the California Energy Commission needs the extra time to ensure that the approved modeling software packages are fully updated. Use this time to refine your designs and still get in under the “easier 2005″ compliance regulations. Here’s the official notice.

EVERYTHING CHANGES AUGUST FIRST: The new 2008 Title 24, which becomes mandatory after August 1, 2009, is 15% more stringent than the 2005 version was, and also creates a whole new set of electronic filing requirements.

HERS VERIFICATIONS NOW MAKE SENSE: Under the new energy code, just to reach basic Title 24 compliance, it will now be necessary to be more creative. For many existing remodels and even for most new construction, it will often be impossible to reach compliance without a HERS rating. Where formerly we strove to avoid the added nuisance of opting for any HERS-rating verifications, the new energy code has changed so that HERS duct testing is now a desirable option which improves the buildings energy efficiency at a minimal cost.

The CEC estimates that HERS duct sealing verifications will now be four times as popular as they were previously under the 2005 Title 24.

NEW ELECTRONIC FILING REQUIREMENTS: Also after August 1, 2009, all CF-4R certificates which are required prior to occupancy must be registered with a HERS provider online (i.e. CalCERTS, CHEERS or CBPCA). Further, after October 2010, all Title 24 documentation including the original CF-1R, which reports the Performance Model, will have to also be filed online with a HERS-Provider.

This now means that any Architect submitting permit applications, in any jurisdiction, will be required by the state of California to have an association with a HERS-provider in order to process their permits online.

WE WANT TO MAKE THIS EASY FOR YOU: Our goal is to remove the hassle of Title 24 for our clients. So, given these facts:

1. HERS-rated duct testing and sealing verifications will now become the least expensive option of choice to reach compliance
2. Our clients will now need to file the CF-1R’s online through a HERS-provider prior to permitting and plans review, and also file the post construction Builder’s CF-6R’s and the HERS-Raters CF-4R certificates on line prior to occupancy

… We at Green Compliance Plus have decided to add HERS-Ratings to our package of complete Residential and Non-residential Title 24 services, so that all these filings can be handled for our clients through our offices.

To do so we have become HERS raters for both Existing Homes and for New Construction, and we have joined CalCERTS as our HERS-provider so that you can have access through us. Also, because we can now do the post construction HERS-verification testing on the project site for you, we now provide complete “Cradle to Cradle” green compliance for your projects, from schematic design to occupancy.