Building Energy Efficiency Standards

Compliance Documents – The Vision

Mazi Shirakh, PEProject Manager, Building Energy Efficiency Standards

July 27, 2015

Title 242016

Standards

Compliance Documents

Compliance Documents – What Are They?Published and updated as part of the Residential and Nonresidential Compliance Manuals

Generally include:

Certificate of Compliance

Certificate of Installation

Certificate of Acceptance – Nonresidential Only

Certificate of Field Verification – Mostly Residential

Worksheets – Generally used for external calculations such as LPDs, area weighted average, etc

Instructions are either included with the CDs or provided in a separate document

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Compliance Documents

What are they used for?

1. Compliance and enforcement – By enforcement agencies for

Plan checking

Field verification

2. In addition, electronic registered documents are used for:

Existing program evaluation

New program development

Incentive programs

Data mining –Contains information about construction practices and equipment and systems installed in buildings

Augmenting RD&D efforts

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Compliance Documents

Why have compliance documents, why so many?

Documents must be submitted to demonstrate compliance with all 11 parts of Title 24, including Part 6 and 11; however, Part 6 forms tend to be more complicated because:

1. Must by law provide prescriptive and performance alternatives in all 16 climate zones, which is a departure from simple mandatory requirements of the non-energy chapters

2. Often require complex calculations that will vary significantly from building to building, examples include lighting power density and HVAC airflow calculations

Having the documentation retained indefinitely can enhance compliance with the Standards

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Compliance Documents

Why so many Compliance Documents?

1. Although there appears to be many CDs (120+ for residential and 99 for nonres), for any given building only a subset of the CDs, may be required

2. For example, there are five versions of MCH-20, Duct Leakage Testing, and MCH-25, Refrigerant Charge and Verification, but only one of each form is needed for a given building; the same is true for many others

3. Also, some CDs are specifically designed to handle either newly constructed buildings, additions, or alterations and may only be used for that application

4. The performance path is used for the vast majority of residential newly constructed building projects and the software generates the CF1R for uploading to a HERS data registry; the registry populates most of the CF2R and 3R with information from the CF1R, greatly reducing the data entry needs

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Compliance Documents - SimplificationCan the number of Compliance Documents and the data input be reduced ?

1.Yes, especially taking advantage of the electronic documents and the HERS data registries

2.All CDs must be reevaluated to determine what information is critical for:

Compliance and enforcement activities

Existing program evaluation and new program development

Data mining

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Compliance Documents - SimplificationCan the compliance documents be further simplified?

1.CDs can be simplified by providing checkboxes that confirm the affected building system comply with the Standards requirements, instead of repeating detailed standards requirements on the CDs as currently done

2.This is a suitable option for complex Standards requirements that do not require detailed calculations, examples are Section 130.0 thru 130.3 – Lighting Controls and Equipment, and Section 130.5 – Electrical Power Distribution Systems

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Compliance Documents – Going PaperlessWhat are the benefits of electronic documents and data retention?

1.Reduces the amount of paper documents that are necessary for compliance and enforcement

2.Can be used by the Energy Commission and others for program evaluation and development

3.Can auto-fill many of the data fields using information for other documents or the registry

4.Ability to reduce the number of signatures required by the same responsible person

5.Allows for data mining – It makes it possible to research the kind of systems and practices are being installed in buildings, some examples include:

Percentage of 2x4 versus 2x6 framing for exterior walls

Verified duct leakage percentage

Type and efficacy of measures installed in buildings, for example mini-splits versus traditional split system air conditioning, or window system types

Data mining may supplement or entirely replace the need for resource intensive RD&D projects

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Compliance Documents – Going Paperless

What are other benefits of electronic documents and registries?

And perhaps most significantly, electronic data retention can supplement traditional enforcement efforts by increasing the risk of liability for “responsible persons” who maliciously claim compliance with the Standards

This approach relies on risk of liability to hold the “Responsible Person(s)” – along with their license - responsible for their work. This approach supplements the traditional enforcement actions and does not replace it.

The success of this approach depends on the existence of the electronic CDs and data registries that retain the compliance documentation indefinitely

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Compliance Documents – Going PaperlessElectronic CDs and data retention may eliminate the need

for nearly all paper forms, forever

Compliance Summary Sheet (CSS)– A new concept that can replace the paper CDs

i.Generated by the registry, one for each project

ii.Lists all registered compliance documents associated with a the project, including CF1Rs, 2Rs, and 3Rs

iii.Electronic CSS includes hyperlinks to each of these forms on the registry associated with the project, which can be used to readily view and print the form; paper forms will include URLs for forms

iv.A CSS could be the only document that is submitted to enforcement agency and left at the site – electronically or paper or both

v.The enforcement agency has the option viewing or printing individual forms by simply clicking on the hyperlinks included on the CSS

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Document Repository – What Is It?

Authorized

Users Data Registry

Energy Commission Document Repository

Keyed-in Data or

Standardized Data Exchange

CF1R CF2R CF3R

The proposed document repository is a central database and electronic document archive application maintained by Energy Commission staff.

1.Automatically receives and retains a copy of each document registered by a Registry

2.All registered documents from all Data Registry providers are consolidated in one central location.

3.Documents are retained in the custody of the Energy Commission thus they are admissible as evidence for enforcement proceedings

4.Supports Building Energy Efficiency Research by a variety of stakeholders

5.Data mining of the full dataset of all registered documents in one central database, instead of queries from multiple Data Registries to get results.

6.Copies of the compliance documents are easily available to satisfy public information requests

7.Software tools to facilitate automated redacted display of document information for public information requests, or for various stakeholder information requests

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Document Repository – Resources NeededResources Needed for Document Repository Implementation

The software development to standardize all residential compliance document data is now complete, thus the only infrastructure not yet provided is the server storage space for the completed files.

1.A URL and storage space on a server at the Natural Resources Agency data center must be approved - this is needed to host the database; for receiving, and for storing the registered document files.

2.IT technical contractor administrative oversight of the Document Repository which would likely only be an extension of the services already being provided for the Report Generator which now resides at the Natural Resources Agency data center.

3.Minimal Energy Commission staff resources should be needed to oversee the Document Repository after it is implemented.

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Nonresidential Compliance Documents1. Currently, there are no registries for nonresidential CDs, all prescriptive CDs are still paper

2. However, The needs for enforcement, program development, data mining, etc, are similar or greater for nonresidential documents

3. Nonres CDs are more numerous and include complicated calculations, especially for lighting, therefore requiring more resources to electronically encode the CDs than residential documents

4. “Electronification” of nonres CDs presents a greater opportunity for compacting the CDs and eliminating duplicative data entry than the residential documents – the process may require redesigning the forms from ground up before “electronification” begins

5. Most of the knowledge and resources developed for residential documents, such as design layout, “Data Dictionary”, and the “Report Generator” can be used for the development of nonres CDs

6. The main missing element is the XML schema development for the nonres document – This may be done by the commission, similar to the residential CDs for 2013 Standards, or by private parties, similar to the 2008 Standards. Development by the Commission will ensure standardization across all documents and registries

7. Over the last year and half, a few private enterprises have shown interest in developing a nonres registry although none has been developed yet

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Compliance Documents

Summary

1. Compliance Documents are needed because Part 6 requirements are more complex than the rest of the building code

2. Compliance documents are used for compliance efforts, program evaluation and development, and data mining

3. Electronic media can result in more compact and efficient CDs, with fewer data input required

4. Electronic media can eliminate the need for printing registered documents

5. Electronic data retention can supplement traditional enforcement efforts by holding the “Responsible Persons” responsible for their work

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Questions?