Codes + Standards, Interviews + Opinion

CLTC’s Cori Jackson on Outcome-Based Energy Codes

I recently had the pleasure of interviewing Cori Jackson, program director of the California Lighting Technology Center (CLTC) and president of the California Energy Alliance, on the topic of outcome-based energy codes. The transcript follows.

DiLouie: What is an outcome-based commercial building energy code and how does it differ from prescriptive and performance-based codes paths?

Jackson: Outcome-based energy codes (OBC) use a building’s actual, measured/metered energy performance as the compliance metric.

DiLouie: What is driving interest in the energy efficiency policy community for outcome-based energy codes?

Jackson: Two primary drivers: 1) OBC can better ensure that energy savings are actually achieved instead of relying on estimates or models and, 2) simplicity. OBC can eliminate all of the complex and lengthy prescriptive requirements and replace this with a list of energy budgets by building type and/or application.

DiLouie: What would a typical building project look like in a perfect outcome-based energy code scenario? How would it be designed, enforced, operated, purchase power, and achieve ongoing compliance?

Jackson: Great question and we don’t know the answers to all these questions yet. In a perfect OBC scenario, the building would be designed according to owners requirements and the architects vision. There would be no limitations in terms of mandatory equipment or features that are currently required by energy codes. Enforcement is one issue that needs to be resolved. Enforcement would require conditional occupancy permits, possibly, or another mechanism that allowed the building to operate in order to capture actual energy use for use in determining compliance. Enforcement would become much simpler for code officials, as well, because they would no longer be required to verify long lists of mandatory building features. Instead, they would verify energy use information provided by the building owner, similar to required energy benchmarking data currently reported to the State of California, possibly. People interested in this topic have discussed performance bonds, for example, as a financial mechanism that could be used to set aside funds for retrofits or corrective measures should a building fail to comply with its energy budget. Again, there is a lot of details to work out among stakeholders before an OBC could be deployed broadly.

DiLouie: Various jurisdictions such as Boulder, Seattle, and the country of Sweden have experimented with outcome-based energy codes. What were the results and lessons learned?

Jackson: Each of these experiments had different outcomes. Some are still ongoing. In Seattle, for example, regulators added a measured performance option to its energy code, but because the compliance documentation requirements were still very complex and the benefits of reduced regulation in some other areas were not enough to offer a sufficient incentive, most buildings did not utilize the option. The lesson there, which is key, is that in order to make OBC enticing to building owners, the reduction in code complexity and mandatory measures must be significant. Otherwise, why subject yourself to the post-occupancy evaluation and possible compliance issues? Boulder is taking a different approach. They are requiring periodic retro commissioning, mandatory lighting upgrades, and some other measures focused on the ongoing performance of a building. I know they are also exploring how to deploy an OBC approach focused on new construction and retrofits that goes beyond the types of single measures they currently have for ensuring ongoing building performance.

DiLouie: There’s been interest in outcome-based energy codes for the past decade. What progress is being made today? Are any jurisdictions on a firm path to implementing such codes, and if so, what is the timeline?

Jackson: I would say that Boulder, CO is probably the furthest along the path to OBC based on what I know. Adopting an OBC is long process, generally. I estimate they are still at least five years away from a full deployment. The California Energy Commission was presented with an OBC option by the California Energy Alliance during its most recent code cycle but they rejected the proposal because their hands are tied by the Warren Alquist Act, which established and regulated the CEC and what it can address. Until that law is changed, the CEC will be unable to adopt an OBC even though I believe there is significant support for it by CEC leadership.

DiLouie: What markets—commercial, residential, new construction, existing construction—are most suited to outcome-based codes? Would a new construction code shift to an existing construction code after occupancy? Would all existing buildings suddenly become subject to code?

Jackson: These are great questions. Right now, OBC, at least in California, is focused on new construction of commercial buildings and major renovations. The residential market, regulating personal energy use, is not something that I think is reasonable. Overall, I think an OBC will be a compliance option when it arrives. Building owners will have the option to use this approach in exchange for a very significant reduction in mandatory energy measures related to specific building designs, equipment or devices.

DiLouie: What are barriers to adopting outcome-based codes, and how can or will they be overcome? What incentives could be built into the code, such as integration with energy providers for favorable rates?

Jackson: I think one of the biggest incentives is simply to eliminate all of the mandatory and prescriptive code altogether. Eliminating hundreds of pages of requirements and allowing building designers and owners the freedom to construct a building that actually meets their needs is huge. Other incentives that have been discussed included expedited permitting and reduced permit costs. In California, permit costs are incredibly high.

DiLouie: What would change for electrical contractors in a jurisdiction that implements an outcome-based code?

Jackson: For the electrical contractor, not too much would change. These individuals would continue to install the electrical infrastructure and devices necessary to meet the electrical code and building design. I think there will be a reduction in the confusion that comes when plans and specifications contradict the energy code requirements, which will be a welcome change.

DiLouie: What opportunities would outcome-based codes create for electrical contractors?

Jackson: I think the opportunities will grow substantially in terms of building automation and controls projects because control systems will be key for OBC-compliant buildings to achieve their energy goals. But with OBC, those systems can now be designed and specified to meet the building owners needs and not to meet some regulation that doesn’t do anything for the building owner.

DiLouie: What impact would outcome-based energy codes have on demand for lighting controls?

Jackson: The demand will increase substantially, in my opinion. Right now with many energy codes, the lighting power densities are so low, that many types of controls don’t make financial sense. However with an OBC, the lighting design teams will be free to do their jobs without such restrictive LPDs, but the building will still need to meet energy budgets or similar energy goals, and to do that, these projects will need good control systems.

DiLouie: What impact would outcome-based energy codes have on preference for technology, such as room- versus building-/campus-based systems? Would these codes drive greater interest in smart buildings/IoT?

Jackson: OBC would definately increase the demand for permantely installed EM&V technology beyond building-level metering, I think. I think the overall trend toward smart buildings and IoT is here to stay, and OBC will only drive that further into the mainstream. But as for specific controls in buildings, that will be building/application specific. Both local and centralized control systems will continue to have their benefits and be used in areas where they make sense.

DiLouie: If you could tell the entire electrical industry only one thing about outcome-based energy codes, what would it be?

Jackson: OBC will simplify the energy code compliance process and significantly increase the use of building controls and automation. OBC will give the electrical industry back the flexibility to design and construct useful structures instead of constructing buildings to meet a list of requirements that may not be useful to anyone once the building is in operation.

DiLouie: Is there anything else that you’d like to add about this topic?

Jackson: If OBC sounds like a good idea, please reach out to the California Energy Alliance. They are leading the effort to develop and deploy an OBC. Every supportive voice counts and they are also looking for early adopters willing to support a pilot at their building or in their town. Get involved if this sounds like something that will improve your business or building.

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Craig DiLouie


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