Removing Barriers to Electrification AIAEB Article, published February 2018 (updated May 2019)

The new round of updates for Title 24 2019 Building Efficiency Standards are in the final stages of creation.  They will go into effect in 2020. While incredibly arcane, these standards, administered by the California Energy Commission, have been the cornerstone of California’s leadership in energy efficient construction.  It is through standards like these and regulations that implement them that high level state policies, such as reducing greenhouse gas emissions to 80% below 1990 levels by 2050, are achieved.

Historically energy efficiency standards and incentive programs have been based on the assumption that natural gas appliances have lower environmental impacts than electric appliances.  However, this is no longer the case.  The dramatic increase of renewables in supplying electricity in California and the development of heat pump technologies for space and water heating have turned this balance around.  If the significant fugitive emissions from gas infrastructure were added to the equation, the scale definitely tips in favor of electric heating.

Building efficiency standards and other programs need to stay current with the science in order to be effective tools in achieving high level state goals. 

The good news in the Title 24 updates is that all electric designs will be given equal standing with gas in single family and low rise residential.  They will have their own baseline for calculating compliance.  In addition, no longer will designs be penalized for using high efficiency, heat pump water heaters.

The bad news is that the new codes will increase penalties for design of all electric, high rise multifamily and commercial buildings because no electric baseline or central electric heat pump hot water model will be available for computer modeling compliance.

In addition, the metric used to calculate building performance, time dependent valuation (TDV), will not be updated to adequately reflect the impacts of natural gas.   The TDV metric is a bit of a black box created by the regulators in 2006 to give value to the time energy is used.  While greenhouse gas emissions and energy use are part of the TDV algorithm, the problem with TDV is that it generally over values natural gas, giving the false impression that natural gas heat is better for the environment than electric.  This was born out in one of the regulators own studies prepared by E3 which showed that in almost every climate zone gas outperformed electric based on TDV but had higher greenhouse gas emissions.

The lack of support for all electric building designs and the continued use of TDV are two areas where California’s energy regulations are not keeping pace with science.  Another is energy rebates and incentive programs.

For example, the ratepayer-funded Energy Upgrade California program, administered by the California Public Utilities Commission, supports tens of millions of dollars of rebates for energy efficiency upgrades including insulation and appliance upgrades. However, these rebates are not available when switching fuels.

To address these inconsistencies, the AIAEB Committee on the Environment members are supporting a coalition effort advocating for climate leadership in Sacramento and across the state agencies to decarbonize buildings.  Cities, environmental groups, architecture and energy consulting firms across the state are asking for regulations and programs to be aligned with state climate goals.  This realignment is absolutely consistent with the AIA’s support of the Paris Agreement and zero net energy in new construction by 2030.

There is no time to lose.  Energy efficiency programs must be realigned quickly to support accelerated reductions in greenhouse gas emissions.