Letter to the California Energy Commission 5.19.17

Dear California Energy Commission,

I’d like to let you know about some failures in the energy code system as I see it in the field as a HERS rater testing alterations of existing houses and new houses.

I work from Silicon Valley to the Wine Country, up and down the Peninsula and in the East Bay Area. I am usually in two or three houses per day. I’ve owned Building Energy Compliance Testing, www.bect.us since June 2014.

What I see is that the only time a house gets HERS tested is when it is new construction, there is an addition or major remodel and it includes a new furnace and ducts. If a homeowner just gets a new HVAC system, it rarely gets permitted and tested. I’ve spoken to other HERS raters and energy consultants, we all suspect that only about 5% of new or altered HVAC systems in California get HERS tested.

Every time I go to a job and meet an HVAC contractor I ask them how they sized this system. They almost always answer, “Square feet.” When I dig deeper into it, they often tell me that the rule is 500 square feet per ton of air conditioning.  Often times, they tell me that the guy at the supply house told them what size to buy. I tell them that the state of California requires ACCA Manual J, D and S calculations. I have one client who I know uses Wrightsoft calcs on every job.

This lack of design before construction causes real problems. I often see 5 ton AC systems on smaller houses in fog banks. Contractors usually fail airflow tests because they wildly undersize cold air returns. This makes the testing process a burden to both the homeowner who can’t get the job “finalled” and has to pay for multiple HERS tests. These big AC systems contribute to peak electric loads, uncomfortable houses and high energy bills.

The problem is with the building department when a job is permitted. When one submits plans for an addition or new construction job to a building department they require structural engineering. What they don’t do is require the engineering on the HVAC system even though the builder or owner signs off on Calgreen and the T24 report and mandatory measures.  Calgreen includes 4.507.2, stating that heating and AC systems shall be sized, designed using ACCA Manual J, D and S.

There is a real disconnect here that needs to be addressed by the CEC, Building Departments and the Contractors State License Board. I’d like to get the heads of these departments in a conference room and have them figure out a way to get energy code compliance above 5% and closer to the majority of jobs.

While I love the fact that the CEC is taking us to Zero Net Energy buildings by 2020, I find it absurd that 95% of current HVAC jobs are not achieving the 2016, 2013 or any other year of the code. HVAC contractors could be the champions of building an energy efficient economy in California. However, what I see is that the vast majority of them are actually outlaws or skofflaws, ignoring codes and evading local building authorities.

Aside from energy codes, these contractors are making electrical and gas connections as well as installing flues to hopefully rid houses of poisonous combustion gasses. These three things are all able to kill people and deserve to have another set of eyes on them. Deaths from carbon monoxide are not a rare occurrence.  

While I am on the job inspecting and testing HVAC systems I look at the insulation installation. Generally, attics are poorly insulated and general & roofing contractors do not use radiant barriers. When this bad combo exists in the attic, homeowners buy air conditioning systems, (even in the foggy Bay Area). We in the energy efficiency industry should be helping building owners install these systems so as not to need compressor cooling and the energy it takes in late in the afternoon at peak load.

Attic hatches are not sealed or insulated in most Bay Area houses. In about the last 90 attics I’ve climbed into, I’ve found 3 that actually have attic hatches that are air sealed and insulated. Insulation contractors just don’t do this. I suspect that since there is no HERS attic hatch inspection no one else cares. In my experience, City building inspectors pass any insulation installation no matter how poorly installed or how many gaps there are around boxes or can lights. Q: When is an R-39 attic actually an R-33.85 attic? A: When the attic hatch is unsealed and uninsulated.

Here is what I’d like to see,

·         Get the majority of HVAC contractors to have their work inspected and HERS tested.

·         Make contractors responsible for 4.507.2, sizing HVAC systems before they build them.

·         Have insulation installations inspected and enforce proper installation.

·         Have attic hatches inspected for air sealing and insulation.

·         Require HVAC contractors get continuing education in the energy code.

I know this is a lot to ask but I request that you coordinate and work with other state agencies like the CSLB and organizations of local building officials to actually enforce the California building energy code. If there is anything I can do to make this a reality, please let me know.

Please do not hesitate to contact me with any questions. My goal is to build a post carbon California Economy.

George Matthews
Building Energy Compliance Testing
Walnut Creek, CA
www.bect.us

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George Matthews
HERS I & II, BPI-BA Single & Multifamily
Green Point Rater for New, Existing & MF
Building Energy Compliance Testing
PO Box 4633, Walnut Creek, CA 94597
www.bect.us  510 520 4443

Failed HERS Test and Final Inspection - How to Avoid the Pain and Expense and a Solution to the Problem

It happened again, yesterday, doing a HERS test on a new house, HERS testing the air conditioning system.
This was the third time I was at this house testing. The technician, not an HVAC contractor but a tech hired by the owner, had added another duct to coax the 5 ton air conditioner into blowing 1750 cubic feet of air per minute, the minimum required by code.

The system did not perform to code. It moved 1600 CFM but not the 1750 required by the State of California. We looked at his work. He'd added a shiny silver drooping limp flex duct connected to a small return filter box. He told me there was nothing more he could do. I suggested pulling it taught in a straight line to the return. He didn't think that would work. He really did not like my alt suggestion of a straight metal duct to reduce air friction.

I exited the front door with him. He threw is boots hard at the driveway and cursed in anger. I could sense deep frustration and a man who probably won't get paid until the job passes. I felt sorry for him. He did not know that these systems are supposed to be sized according to manual J, Manual D and Manual S in software such as Wrightsoft. The owner or builder had signed off on building to the Calgreen checklist which states that the HVAC system will be sized according to Manual J, D and S. Apparently, no one took that seriously. The City of Orinda building department never asked for this basic engineering. Hence, it never got done.

The technician had guessed the system together. The 2600 square foot house in mild, often foggy Orinda, California somehow received a 5 ton air conditioner, the largest available. When it failed he asked me what to do. I had to tell him that I am not the designer but the State's Energy Commission does have something called the Building HVAC Requirements.  http://www.energy.ca.gov/2013publications/CEC-400-2013-001/chapters/04_Building_HVAC_Requirements.pdf

In these Building HVAC Requirements, under table 4-11 (Standards Table 150-D): Return Duct Sizing for Multiple Return Duct Systems, there is a line that shows a 5 ton air conditioning duct system having two 20 inch return ducts with a minimum gross filter grill face area of 1500 square inches.

The system I was testing did not have anywhere near 1500 square inches of filter grill face. It had two filters equaling 768 square inches, about half what code is requiring.

If this system had actually been designed rather than guessed together by a person using some "rules of thumb", it most probably would have passed the first time. The problem is that this is the 3rd time I've seen this in a ten days. It happens all the time in the affluent, well educated San Francisco bay area, home to so much energy efficiency research and development.

I usually ask air conditioner contractors how they sized the system I'm about to test. Almost invariably they tell me they use the "square footage rule". "What is that?" I ask. They then explain that for every 500 square feet of house they put in a ton of AC. Easy! 2500 square feet of house equals 5 tons of AC. System sizing complete! Sometimes they admit that the guy at the supply house told them what size was needed.

We know the problem. HVAC contractors and unlicensed technicians who install HVAC systems don't size those systems according to protocol of the Air Conditioning Contractors of America. The results are brand new, shiny yet poorly operating systems that will waste energy and perform poorly for decades to come.

Here's the solution. City Building Departments must get manual J, D and S designs before contractors can build that system. Just as seismic engineering is required for buildings before they are built, so to can we require that mechanical systems be engineered before they are built. Then we just have to work with the problem that the residential HVAC industry evades building departments permits and code HERS testing some 90% of the time.

A call to action for Bay Area Cities

Video: Bringing Building Performance Workshop to the San Francisco Bay Area

Hi, I am George Matthews of Building Energy Compliance Testing, BECT, of the San Francisco Bay Area.

BECT is sponsoring the Corbett and Grace Lundsford of the Building Performance Workshop to come to Bay Area with the tiny house that they built as a tiny building science laboratory and idea house on wheels.   This is their Tiny House/Proof is Possible - US Tour 2016.

Video: Show Pic of SF Bay Area from maps.google.com

Corbett wrote the book on home performance diagnostics, literally, here it is. Corbett is a superstar of building performance who had created scores of high quality building performance diagnostic videos – Here is your chance to meet and learn from him.

Corbett, Grace and their baby daughter Nanette (and two cats!) are traveling across the USA showing off building energy science and diagnostics in their tiny house lab and they need some places to park it give tours and classes plus show it off from October second to the eighth 2016. That’s next month!

City of San Francisco, Berkeley, Palo Alto, San Jose, Sonoma County – You are the leaders in civic energy. Can you lend us a parking spot next to your Building Department?

Please contact us at 510 520 4443 or bectesting@gmail.com if you’d like us to come to your parking lot with curious people.

Proof is possible - come find out how on the Tiny House 2016 Tour – San Francisco Bay Area

This is George Matthews at Building Energy Compliance Testing, BECT

Things HVAC contractors should know before installing a new system in California (to pass the 2013 energy code)

I keep running into HVAC contractors still unfamiliar with HERS duct leakage tests, total airflow and fan/watt draw tests to pass in the 2013 California Energy Code. This is from the BECT.US website for all to see but I keep having to explain it while a distraught contractor, technician or homeowner asks what is wrong. 

Important Items for Installing HVAC contractors to know:

Please note: The 2013 energy code, Title 24, requires quite a few things in an HVAC system. Here are some highlights.

• HVAC system sizing must be calculated by an approved method. Duct systems are required to be designed by an approved method. ACCA Manual J and Manual D are one system to do this. Wrightsoft is the leading software tool. “Rules of thumb” sizing do not pass code or work well. I know one contractor who was sued for using them rather than a code approved method
• 
  
• Air conditioners need to have at least 350 CFM per ton of air flow. A/Cs need to use 0.58 or fewer watts per cubic feet of air flow. This is the code absolute minimum. Here, more airflow is better.
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• You’ll need to have the cold air return properly sized. See above. Again, Bigger = better. I keep running into contractors with wildly oversized furnaces and air conditioners who balk at the idea of using anything larger than a 16" return duct or that two large returns might be better than one small one. 
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• You’ll need to state the airflow the filter system is rated for. The registry will want to see .05 inches of water column of pressure in the return and .10 in the supply. Are you sure the return grill from 1955 (heat only) is big enough for the new system (with AC) in 2016?
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• You’ll need to tape the sheet metal boots to the drywall or flooring. Use UL 181 aluminum tape.
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• You’ll need to mastic over the tape that is sealing your system. Really, yes.
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• Use only “UL181” approved plastic and metal tape and mastic. UL 181 is code required.
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• You’ll need to have less than 6% duct leakage in new duct systems and less than 15% in existing systems. (FYI: Hot rodder contractors get their systems below 1 percent.)
• 
  
• (Note: the secret ingredient here is air duct mastic. Use it liberally. Put it on every connection. It is cheaper than having to pay a HERS Rater to come back and retest the system.).

 Missing any of these items is a failure, so take heed.

It gives me such joy to see a system that holds air when I set-up the duct test equipment. I hope that you enjoy it as well.

George Matthews
Building Energy Compliance Testing

Post War California Tract House Energy Audit Reveals Room for Improvement

Postwar, 1947 tract house on 1/3^rd acre lot is inundated with sun since the old trees died. The owners are doing a remodel. West facing single pane windows let in ample sun and warmth on a February 1^st afternoon. By April or May it will surely feel like a furnace. New, California Energy Code level windows formulated for western orientation will make the dining/living room more comfortable year-round.

The house has no insulation in the floor or walls. The ceiling has about 3 ½ inches of old, disturbed, blown in insulation. Building a dam around the fold-down access stairs and furnace and insulate it to R40 (about 14 inches of blown-in cellulose) would make the place far more comfortable and cause the furnace/AC to run less often.

The attic access is an area where warm conditioned air escapes to the attic, causing drafts and wasted energy dollars. Those fold-down access stairs to the attic are really hard to air seal or weatherstip properly. I suggest adding on one of the zip-up “tents” that go on top of the access area.  I’d never seen one until last fall. They are air tight and really work.  Check out one site selling such “tents”, http://www.energyefficientsolutions.com/attic-tent.asp

That same attic, under a brown roof must surely bake in the summer sun. I suggest adding radiant barrier under the roof deck. You really have to feel the difference to believe how much energy this material stops from radiating into the attic. It works! Check out http://energy.gov/energysaver/radiant-barriers  to learn more. For a low tech way to go, here just paint the roof white. They do it from the Bahamas to India to the Greek Islands. Put on your sunglasses and check out Santorina, Greece, cool…
 

The crawlspace is open and ventilated to the outside with no insulation in the floor. Many would suggest adding R19 fiberglass  insulation to the bottom of the floor. That is an imperfect way to go. A more interesting and healthy option is to encapsulate the crawlspace. This action can not only keep the floor warmer in the winter but keep the nasty air from the crawlspace out of the house. I’ve read articles stating that over 40% of the air in a house comes up from the crawlspace. Below is a before and after pic that shows the visual improvement. The lower pic shows how a crawlspace can become a semi-conditioned sub-first floor that seems more like an operating room than a crawlspace.

il. Above Left: Thick plastic separates house from soil
Right: Americover.com materials encapsulate crawlspace

The water heater is a standard .62 tank water heater that takes up a significant amount of space in the garage. The owner mentioned how an expanse of pipes makes the cold water hot in the summer months.  An upgrade to an instantaneous gas water heater could both free up space and provide energy savings.  The pipes could be insulated to reduce heat gain.
Takagi Instantaneous gas water heater saves space and energy

The house has a newer large furnace/air conditioner system that appears to be well sealed except for a small leak on the right hand side of the furnace. Place UL 181 aluminum tape on the corner of the plenum to seal it.  The flex ducts appear thoughtfully sealed however they all leak unless there is mastic on the joint of duct to the plenum. Twelve dollars worth of air duct mastic and an hour spreading it around every duct connection would surely keep more air inside the system and the house rather than in the attic.

Doing the above items would render the house more comfortable and lower the energy bills. How much? To learn that, computer energy modeling is necessary. Your energy consultant could easily model them and assign dollar values.  The nice thing about the upgrades is that they offer non-energy dollar benefits of  improved air quality, added space and improved thermal comfort.

Building Energy Compliance Testing

www.bect.us

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Duct Testing in the San Francisco Bay Area/Silicon Valley

Reasons why HVAC Contractors (and the Developers they work for) Fail HERS Tests.

This week I had two notable tests where the developers of a brand new houses failed his HERS test. These are new houses built under the 2013 California Energy Code.  Both houses had HVAC systems that failed to move enough air to satisfy the Total Airflow requirement when there is air conditioning. Both systems had the largest residential air conditioner that one can buy, a 5 ton condenser and matching evaporator coil.

With a 5 ton condenser, to provide 350 CFM of airflow per ton, you’ll have to provide 1750 CFM. This week’s problem units had 1230 and 1410 CFM. Given those numbers what does an HVAC contractor do to solve the problem so that he can satisfy his client and pass the code requirements so that the house can pass final inspection? Pick one strategy.

A.      Rewire the control board so that the system is actually in the highest speed.

B.      Replace ducts, especially the return ducts, with bigger diameter replacements so that the airflow will increase.

C.      Change out the motor in the furnace or air handler to an electronically commutated motor to get a higher airflow.

D.      Change out the condenser for a smaller size so that the airflow/ton rule is met.

E.       Tear out the system and hire an HVAC contractor who will actually perform a manual J, Manual  D, manual S and Manual T so that the system is guaranteed to move the proper amount of air to each duct and each room.

I’m still waiting to hear back from the owner/developer to hear how these went. However, in the last 6 months I’ve seen contractors and owners do A, B, D and E.  I’ll comment on each strategy.

A.      Rewire control board connections. - This is a common problem I see weekly where a tech will change the wiring and/or the dip switches and the unit immediately moves more air to pass the AF test. It shows why the HVAC contractor really wants to have a tech on the job when the HERS testing happens.

B.      Replace ducts. I see this fairly often. The HVAC contractor adds another return to the master bedroom or enlarges the return duct from 16 to 19 inches, more airflow happens, and the problem is solved.

C.      I have never seen this one done but know from PG&E sponsored commissioning classes that one can use Motormaster software and dial-in a properly sized motor for any application. That same class will tell you how extremely common it is to find wrong sized motors, pumps and fans throughout the built environment.

D.      Change out the condenser for a smaller unit. If you have a 5 ton system that is delivering 1230 CFM, changing to a 3.5 ton condenser works.  Just changing the condenser may be easier than re-doing the ducts.  Make sure it is 14 SEER, 13 no longer passes.

E.       Owner tells HVAC contractor to pull out non-code compliant system and hires contractor B who follows code and performs load calculations, duct design and then tests the system himself to make sure that every duct and every room is getting the airflow that the right-soft software said was necessary for proper performance. 

This one happened to a contractor a few weeks before Christmas. The contractor was expecting to get the final $14,000 payment mid December and pay his supplier and employees. He probably would have used that money to buy some Christmas presents for his family. Instead, that guy got a tough lessen in why a contractor needs to conform to the code.

Filter Grill Requirements Update from the CEC

While testing at BECT.us I have come across a number of air conditioning systems that do not meet the total airflow and fan/watt draw levels of performance that the code calls for. When this happen the HVAC contractor has to redo the return duct design and then install it at significant cost of time and reputation. It shows that the system was never actually designed but pieced together using a best guess. There has got to be a better way.

The CEC has just sent out an update of their filter grill requirements which are a critical part of the return duct system. Here is there update.

"Filter Grille Area Requirements

When complying with the Alternative to Section 150.0(m)13B, the nominal size of the air filter media should be used to calculate the minimum total return filter grille gross area. If the air filter is not located at the filter grille, use the nominal size of the filter grille to determine the area. The calculated area must be equal to or greater than the values in TABLES 150.0-C or D.

Additionally, TABLES 150.0-C and D also require that:

 1. Each return duct must be no longer than 30 feet.

2. Each return duct must not have more than 180 degrees of total bend.

3. If the total bending of a return duct is more than 90 degrees, one bend must be a metal elbow.

4. Return grille devices, which include the air filter and return grille locations, must be labeled in accordance with the requirements of Section 150.0(m)12A.

 5. The label must state the grille’s design airflow rate and a maximum allowable clean-filter pressure drop of 12.5 Pa (0.05 inches water) for the air filter, as rated in accordance with AHRI Standard 680 for the design airflow rate for the return grille. Please note that additional air filtration requirements of Section 150.0(m)12 may apply."

I've seen some contractors who were shocked at how much filter area the code was calling for. Of course, the best way to make sure that the filter grill requirements are met is to use a proper duct design system such as Right Soft. The vast majority of installations that I see are not designed at all.

I hope that bringing this to light could alleviate some of the pain I've seen in the eyes of someone who has to redo their hard work often in a sweltering attic.