Introduction. 1. Attendee List. May 20, 2010 California Lighting Technology Center
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1 A c c e p t a n c e Te s t i n g a n d D e s i g n P h a s e C o m m i s s i o n i n g To p i c s T i t l e 2 4 F i r s t S t a ke h o l d e r M e e t i n g Introduction May 20, 2010 California Lighting Technology Center This memo summarizes the key discussions that were held during the first Investor Owned Utility (IOU) sponsored 2011 Title 24 stakeholder meeting for Acceptance Testing and Design Phase Commissioning topics. The meeting was held at the California Lighting Technology Center May 20 th Most of the discussions focused on the specific code change options presented and the proposed methods of analysis or presentation of data. For a full understanding of the scope of each code change proposal, this memo should be read in conjunction with the power point materials that were presented at the stakeholder meeting. 1. Attendee List In person: Pat Eilert Pacific Gas & Electric Matt Tyler, Glenn Hansen Portland Energy Conservation, Inc (PECI) Karl Stum Summit Building Engineering Mike McGaraghan, Elizabeth Joyce Energy Solutions David Dias Sheet Metal Workers Bradley Brooks HDR Inc Seran Thamilseran California Energy Commission Tom Garcia City of Fairfield, CALBO Energy Committee Sahar Abbaszadeh CTG Energetics (Construction Technologies Group) On the phone: Charles Kim, Randall Higa Southern California Edison Gary Flamm, Jeff Miller California Energy Commission Bill Falkenhayn Cadmus Group Lynn Benningfield Benningfield Group, Inc. Lee Stevens - Emerging Technologies Associates, Inc.
2 Contact Information for CASE Measure Leads: Matt Tyler, PECI (Projects AT 1 & 2) mtyler@peci.org Karl Stum, SBE (Design Phase Cx project) kstum@summitbe.com Glenn Hansen, PECI (Design Phase Cx project) ghansen@peci.org Elizabeth Joyce, Energy Solutions (Projects AT 1 & 2) ejoyce@energy-solution.com x TOPICS DISCUSSED 2.1 AT 1: ACCEPTANCE TESTING PIER STUDY (COMPLIANCE AND ENFORCEMENT) Overview: This measure seeks to improve low acceptance testing compliance and enforcement activities, via research being conducted under a CCC (California Commissioning Collaborative) PIER (Public Interest Energy Research) study. Comments, Suggestions: Brad Brooks: Notes that there is also a lack of direction from the engineer community; engineers are not putting the AT forms in as part of the building plans. CASE leads should interview engineers as part of research activities; currently interviews are limited to building officials, building owners, and contractors. Gary Flamm notes: he s made presentations to electrical engineers, and their concern is that no one is paying for these tests, and no one is specifying who does the tests. The assignment, responsibility, and payment are not accounted for. Matt: Agrees, if no one assumes this is their responsibility, it won t be included in the bid and budget. Discussion: Mike McGaraghan: Asks how PECI intends to select the various phone interviewees and test sites? Matt: SMACNA, the CCC, Jon McHugh (of McHugh Energy Consulting), and Erik Emblem (of SMACNA) are involved in train the trainer classes for outreach to building officials. PECI will use these lists to begin generating the call list. PECI also has contact information from PECI s retrocommissioning (RCx) programs. Pat Eilert: Asks how PECI will locate these buildings? Matt: PECI will look at existing buildings through their RCx program and during building department interviews and visits. Pat: Is there any advantage to conducting these tests on new buildings, not existing buildings. Matt: There could be some advantage, although the purpose is to test the acceptance tests more than testing building equipment for pass/fail results. New, large commercial buildings will not be ready for test in time for this project. Hopefully, PECI s research will include some newer buildings. Pat offers to give Matt list of new buildings through PG&E s SBD (Saving by Design) program. Pat also notes he has gone through RFQ (request for quotation) process for selecting contractors; Pat can provide PECI
3 information on how to do this. Matt will follow up with Pat on getting newly constructed buildings through SBD. Bill Falkenhayn: Notes that the official code date is the date that permit is applied for; there is a lag between date the permit is pulled and construction occurs (~9 mos). Matt: asks if grandfathering is then an issue, where a building might be able to be built under 2005 standards? Bill notes that the biggest problem is the difficulty of tracking which code version applies. Matt notes that the savings estimates from the 2005 HMG report (used as part of the 2005 CASE process) assume 100% compliance for the acceptance tests noted there. These estimates were done using DOE-2 energy simulation software. Pat: asks if for these efforts Matt estimated costs? Matt: Yes, we timed the contractors performing tests, and apply hourly rates for different regions of CA (for inspections, testing, and completing forms). Tom Garcia: Asks how many acceptance tests are in the standards? Matt: 21. Tom Garcia: Thinks that simplification of forms and testing may help; some data in the form may be superfluous, and may drive people away by excessive complexity. Seran Thamilseran: Agrees; forms aren t pulled because of this complexity, so building departments don t get them. Karl Stum: Asks if PECI is considering adding or taking away acceptance tests? Matt: No, this project is focused on improving the tests and process, to increase compliance rate and level of enforcement. AT-2 will add tests. Mike: Notes that other CASE projects are also looking at adding/dropping acceptance requirements, but this particular project is mostly about the system and process. 2.2 AT 2: ACCEPTANCE TESTING BASED ON RCX FAILURE MODES Overview: This measure will review a dataset of over 800 failure modes from 125 buildings, obtained from PECI s RCx program during These failure modes will be filtered by frequency and potential energy savings, and the results used to suggest new acceptance requirements that would address key building failures. Comments, Suggestions: Mike: Notes that after analyzing the data from these programs, it may turn out that these failure modes are already being addressed by current (2008) standards. Brad: Raises the issue of maintenance; maintenance staff may change or augment some of the building operation modes, which will affect savings and failures over time. This should be accounted for in the PECI data analysis. Karl: Notes that this RCx dataset may also inform current tests that are unnecessary, because those failures aren t identified as common or significant. Discussion:
4 Bill: Asks if these failure modes all correlate to actual codes? Matt: Believes there already may be codes that address some of these failure modes, but there may be opportunity for improvement. Seran: Agrees, some of these items are already under the T code, but may still need to be addressed and improved. Sahar Abbaszadeh: Notes that the earlier 2005 CASE study for acceptance tests was based on assumptions of failure frequencies. Perhaps with the current dataset, PECI could reevaluate the old failure frequencies, to account for how common these modes are? Matt: Has no intent to do this, sees it as a calibration exercise. The bigger issue and priority is addressing the low compliance rate rather than refining the savings estimates. The acceptance requirements adopted in the 2005 and 2008 standards were proven cost effective, thus no need to revisit. Brad: Asks if PECI is planning to look at the actual energy savings, i.e. verify energy simulation with in-field measurements? Matt: Thinks this may be a part of the Cadmus M&V effort. Bill: Is not sure what Cadmus level of engagement is, Bill needs to ask Allen Lee (of Cadmus). Pat notes that Cadmus has just now finishing the 2005 EM&V (Evaluation, Measurement, and Verification) report. CPUC was supposed to finish reviewing it in October, and all are waiting for reports to be published. 2.3 DESIGN PHASE COMMISSIONING Overview: This measure seeks to use commissioning best practices, particularly related to early design decision-making processes, to inform changes to the code that will improve energy use and building operation. The intent is to clearly define what commissioning best practices need to be defined during the design phase and emphasize the importance of design review. Minimum design phase requirements will be proposed as a new code measure. This measure will obtain information primarily through interviews with building designers, commissioning providers, code officials and other stakeholders. Suggestions, Comment: Glenn: This project intends to build off newly defined Commissioning requirements under CalGreen which becomes effective CalGreen, however, does not require design review, which Glenn and Karl think is an important element. Discussion: Brad: Notes that CalGreen is coming out in January 2011, and except for that code, there aren t any codes / standards existing today that require a design review or commissioning. Karl: Notes that CalGreen actually doesn t require a design review (though it does require Cx). Glenn Hansen: One element of this measure is to link acceptance testing into early design phase, ensure that it s included in the design and coordination from the start. Pat: Asks what causal effect PECI is looking for in doing this? Glenn: They seek to identify and assign responsibility for these tasks. Brad: Raises another issue with designers: designers / engineers currently take responsibility for the design but not for the construction phase (which is seen as the role of contractors). Designers don t want the liability of having to sign
5 off on the acceptance forms. This should be addressed. Brad: Asks whether Glenn and Karl have a recommendation on who will do these design review or Cx tasks? Glenn: It s on-task; is yet another point of the issue of who takes responsibility. Gary Flamm: notes that on the issue of responsibility CEC was purposely vague in writing this language because they wanted / expected the market to determine who would do it. Tom: Asks will any Cx requirements be case-sensitive for certain types of equipment or systems? Glenn: Notes that CalGreen currently requires Cx only for buildings above 10,000 sf. Pat asks Tom: What is the responsibility of local governments as required by something like CalGreen? Tom: Notes that it s not well-defined. There s a local interpretation in every building department. Through the next code adoption process, code leads will have to better define when Cx activities would occur, and who precisely would do it. Brad: Notes that from experience, the owner s project requirements (OPR) in particular are typically hard to pin down and change throughout the process. Tom: Thinks that owners will have to be persuaded to want this, and realize its advantages. Tom notes the issue of commercial space: the energy savings go to the tenant, and not the owner who pays for extra design measure. Glenn: Notes that ARRA (American Reinvestment and Recovery Act) funds are tied to a national 90% compliance goal (with ASHRAE 90.1) by Sahar: Asks if ASHRAE 189 requires a third party for commissioning? Glenn: Doesn t know, suggests to refer to ASHRAE Guideline Zero. Karl: Notes that ASHRAE has not tried to specify or assign responsibility for commissioning. David: Asks whether could use BIM (building information modeling) process for design phase commissioning? Thinks it could be possible. Brad: Notes the common problem of using a third party; there is no enforcement unless the code is strong enough to say that there must be checks and balances. Brad recommends either 3 rd party commissioning, or using some other party who s not involved in the design and construction. David: Suggests also including some other kind of protection or penalty for bad reports or practices. Tom: Notes that this falls in line with special inspections; a building inspector passes it and building department must agree. Tom suggests including testing checklists as part of contractor responsibility, and bid it upfront. If a contractor knows it s required and clearly included, the majority will do it. There may also be a possibility for additional spot checks. Gary: Notes the strict signature requirement currently in place for acceptance tests; even if the controls person is the one doing acceptance tests, the engineer has their license on the line. Brad: for small buildings, there s limited quality control and Cx. Larger buildings, however, use a much better and different approach. Therefore, should have different Cx-type requirements for different buildings. Karl: Thinks that now we need to figure out how to integrate CalGreen Cx items with actual practice and the rest of the baseline code. As far as responsibility he thinks that the issue is not only who is in charge, but who does the actual work.
6 Elizabeth: Asks if CEC has the authority to specify responsibility for testing or commissioning items? Karl: notes that from experience with LEED, which didn t specify who has to do owner project requirements, etc., no one took responsibility. Therefore, it s now explicitly stated in LEED who writes OPRs (Owners Project Requirements), who funds OPRs, etc. Seran: Raises HERS as an example of a successful third-party program. Pat: Asks if anyone has discussed extending HERS to small commercial buildings? Matt: Notes that this was a proposed measure by AEC (Architectural Energy Corporation) with the CEC, but he isn t sure if it s still intact. Seran: will ask Martha Brooks about that status of that project. Pat: Thinks that if the infrastructure exists in HERS, it would be possible to extend it for some small systems. David: Asks what counts as small commercial? Glenn: Notes that CalGreen requires TAB (testing and balance) for buildings less than 10,000 square feet (which don t require Cx). Randall Higa: Asks Tom Garcia regarding including Cx requirements in the spec; Randall thinks that plan checkers don t look at the specs. Tom: We don t spend a lot of time on the specs, look at the plans more. So he thinks it would be useful to put Cx requirements on the plans instead of the specs. Karl: Raises one possibility: to have a checklist for design team relative to the specs, that insures that certain elements are put into the specs. Then the building department would only have to look at the checklist from the design team. Randall: Asks the scope of what s in Part 6 of Title 24 (base code) vs. Part 11 (CalGreen)? Does it make sense to put additional Cx requirements into CalGreen, or into part 6? The issue is whether there could be diff requirements in CalGreen vs. in the base code. Tom: Agrees, we need to avoid areas of unnecessary overlap and complexity between the two. Randall: Raises another scope issue ASHRAE 189 only covers design/construction/operating plan. They cut the coverage off after that point because they don t want to regulate after certificate of occupancy. But, AHSRAE 189 does require designation of a project Cx authority, to oversee Cx tasks. Additional Information and Links Additional information can be found at the Title 24 Codes and Standards Enhancement (CASE) website,
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