Building Energy Codes as Compliance Options in the Clean Power Plan 3N Meeting December 4, 2014 Bill Prindle, Vice President

Transcription

1 Building Energy Codes as Compliance Options in the Clean Power Plan 3N Meeting December 4, 2014 Bill Prindle, Vice President 1

2 Agenda Codes potential role in CPP compliance ICF s Codes and EE Analysis Code compliance issues Metrics energy vs. buildings Compliance measurement and verification State example: Illinois Discussion and next steps 2

3 How can States use Energy Codes in CPP Compliance? Key Questions/Issues: Emissions-rate compliance pathway vs. mass-based/total emissions pathway M&V issues more challenging in emissions-rate pathway Are codes seen as part of or in addition to the 1.5% energy savings assumption EPA used in the proposed rule EPA s number is based on state ratepayer-funded EE programs, relatively little impact on new construction Some analysts (e.g. EPRI) think 1.5% from utility programs alone is not sustainably achievable, so codes might fill the gap Others believe 1.5% is too conservative, and codes should be used to expand EE targets 3

4 State Precedent for Energy Codes in CAA compliance Texas model: statewide energy code included in NOx SIP Enabled by extensive analytics from TAMU-ESL Egrid data used to develop ecalc emissions calculator ecalc supported integrated reporting of emissions reductions from codes and other measures Codes credited with 4.5 ton/day Source: Texas A&M ESL 4

5 ICF s overall EE and codes analysis Overall, national-scale EE analysis Used IPM to estimate U.S. costs of electricity production under 4 scenarios that varied by Policy: With and without CPP, modeled as state-specific tradable rate standard similar to EPA s Option 1 State Case EE level: No incremental ( Frozen ) and EPA BSER ( Additional ), consistent with penetration assumed in EPA Regulatory Impact Analysis Used the difference of differences to estimate the incremental value of EE as a compliance mechanism under the proposed CPP rule 5

6 Billion 2013$ National-scale findings: Overall EE Under CPP, EE reduces system costs $32B-$44B in EE cost reductions are $4-6B greater under CPP than without it CPP increases EE value by 14-15%, or about $.012/kWh Incremental Value of EE under CPP 6 $14 5 $ $10 $8 $6 $4 2013$/MWh 1 $ Billion $ $/MWh $- Source: ICF 6

7 National-scale EE codes findings ICF conducted further analysis based on its EECC code development analytics to show the energy and emissions impacts on a state-by-state basis. Impacts of across the board adoption of the 2015 IECC and ASHRAE energy efficiency codes. Assumed energy code compliance rates, ranging from 80-95% Initial results indicate annual incremental savings > 3 TWH, or at least 6-8% of the EPA Block 4 savings assumption Cumulative savings could run to 52 TWH or higher, and 7-15% or more of the EPA cumulative savings estimate Savings estimates being refined: differences can stem from key assumptions including baseline construction practice, compliance rates, building simulation and market characterization parameters 7

8 Code Compliance Issues Policymakers want to know code-based savings will be real But: for 111d compliance, the level of M&V needed can differ For tradable-rate pathways, M&V must be strict For mass-based/hybrid pathways, M&V may be less strict Compliance metrics also matter Some studies use # of fully-compliant buildings as a metric Others use % of energy savings as a metric % savings numbers typically higher than # compliant buildings Key trends affecting code compliance HERS ratings gaining large market share IECC 2015 includes HERS as a compliance path Utilities in some states asked to support code compliance programs 8

9 Code Compliance Emerging Practice Methods available through Sample Generator TM and Score and Store TM tools, survey instrument, compliance checklists Best-practice approaches include: Baseline (pre-program) study using Sample Generator and survey Simulation methods to calculate baseline building-level energy use Construction projections used to calculate jurisdiction-wide usage Training, admin and tech support, third-party inspection services Post-program study repeats pre-program Simulation methods calculate energy usage attributed to program Program impacts calculated based on percentage-compliance increment, e.g. 10%, 20%, 30% Key is to isolate incremental savings; baseline need not be perfect Technical and admin support available from PNNL, BCAP 9

10 Code Compliance Utility Program Example: Illinois CANDI program engages 5 investor-owned utilities accounting for most of the state s construction activity Follows the best practices model: Establishes a statewide energy code compliance collaborative Provides administrative Support to Municipalities Establishes a comprehensive training program Develops and disseminates informational materials Initiates a jurisdictional assistance program Establishes an Equipment Leasing Program Implements a third party plan review/inspection program Costs estimated at $3.4 million/yr, $10.8 million over three years Subjected to state PUC cost-effectiveness tests 10

11 Utility Code Compliance Role vs. EPA Approvability Criteria Treatment under compliance pathways: Tradable-rate pathway would require more rigorous M&V Mass-based pathway may not require the same level of M&V Enforceability: 111d gives PUCS a policy rationale for utility role in code compliance Utilities get savings credit based on compliance improvement Achievement of emissions performance: Emission-reduction calculations for end-use EE are indirect Utility programs can be designed to document code compliance PNNL-developed methodology provides compliance calculation basis Quantifiability/verifiability of emissions reductions: Utilities can document compliance under PUC/DCEO oversight PNNL, NEEP, other methods are available 11

12 Utility Code Compliance Role vs. EPA Approvability Criteria Non-duplicativity: Utilities with above-code new construction programs will need to segment attribution from code compliance efforts Permanence: Codes measures have high persistence typically permanent building shell measures or 15+year HVAC measures Ratepayer-funded program measures average ~10 year lives Report process: PNNL and other methods include reporting States can oversee/fine tune reporting Budget/Funding Source: Adoption: construction industry Compliance: utility ratepayer funds 12

13 Discussion and next steps What are the key policy and analytics questions that must be addressed to advance energy codes in CPP compliance? Place of codes in state s overall compliance strategy Relationship to ratepayer-funded program impacts Compliance, EM&V issues Role of utilities in compliance Others? What do NASEO, NACAA, NARUC and their members need to advance the use of energy codes for CPP compliance? Further analysis Technical tools Technical assistance Others? 13

14 Contact information Bill Prindle, Vice President