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