White Paper - Energy Code Update

The Energy Policy Act of 1992 amended the Energy Conservation and Production Act (ECPA) to establish ASHRAE/IESNA 90.1-1989 Energy-Efficient Design of New Buildings Except Low-Rise Residential Buildings as the Federally mandated minimum design and construction standard for commercial buildings throughout the United States.

ECPA also empowers the U.S. Department of Energy (DOE) to review any updates to Standard 90.1 and determine whether such upgrades would save energy over previous versions. When DOE made a positive determination for the 1999 Standard, it triggered a two-year window that required all 50 states to certify by July 15, 2004 that they had commercial energy codes in place that are at least as stringent as 90.1-1999. Standard 90.1-1999 is also referenced in the 2001 version of the International Energy Conservation Code (IECC).

As of October 2004, 18 states have still not yet achieved compliance, already costing organizations in these states an estimated more than $14 million in higher energy costs per year based on construction trends, according to David Weitz, Executive Director for the Building Codes Assistance Project (BCAP).

Two years ago, in September 2002, about two months after the DOE ruling was published in the Federal Register, 18 states had energy codes that met or exceeded the requirements of Standard 90.1-1999, 15 states met 90.1-1989, and 17 had a weaker code or none at all.

Two years later, in October 2004, 32 states have energy codes that are at least as stringent as Standard 90.1-1999, with some adopting even stricter codes, such as Florida and California. Of these, 10 states—Arkansas, Georgia, Kansas, Maine, New Mexico, Nebraska, Utah, Pennsylvania, Montana and Rhode Island—have adopted the 2003 IECC/ASHRAE/IESNA 90.1-2001 as the basis for their energy code.

“Over half the states in the country either have codes in place or soon to take effect that meet or exceed Standard 90.1-1999,” says Weitz. “These 28 states account for over 70% of new commercial construction in the U.S. In addition, the trend seems to be for more states to climb on board with either adopting the code or updating to a more current version than the one they have in place. So the code is definitely having an impact.”

In short, the states have made good progress, but a significant number did not make the deadline, and continue to inch towards adoption of a new code. In fact, 18 states have still not yet adopted a code that complies with the Federal legislation.

Of the states that have not yet adopted a suitable code, Hawaii, Wisconsin, Minnesota and Indiana are currently in the midst of the process of developing one. Louisiana, Oklahoma, Virginia and Iowa (plus Washington, DC) have Standard 90.1-1989 in place, but have not yet begun the process of updating their codes to Standard 90.1-1999. Mississippi, Wyoming, Alaska, Nevada, Arizona, Colorado, North Dakota, Missouri and Tennessee have either a weaker code than Standard 90.1-1989 or no statewide code at all, and have not begun the process of developing one. Some of these states, such as Virginia, have filed for extensions, promising action that has yet to be realized.

The biggest obstacle appears to be inherent in the constitutions of the “home rule” states of Nevada, Arizona, Colorado, North Dakota, Missouri and Tennessee. In these states, it is exclusively up to local cities and towns to decide if they want to adopt the code or not. “One reason for states not complying with the July 15 DOE deadline is that some states simply have no mechanism to impose a statewide code,” says Weitz. “However, there are many cities that have adopted the code in home rule states.”

The other problem is that the legislation does not specify any penalties for states that fail to adopt an energy code at least as stringent as Standard 90.1-1999.

DOE has yet to make a formal determination on Standard 90.1-2001. The 2004 Standard is due out this month. Some anticipate that in 2005 or 2006 DOE will make a positive determination that Standard 90.1-2004 will save energy over the earlier version, again starting the two-year clock for states to certify that they have updated their codes. This means that we can anticipate adoption of even stricter energy codes across the country in 2007 or 2008.

Figure 1. Commercial code compliance as of October 2004. Courtesy: Building Codes Assistance Project.

To see Figure 1, click here. It will open in a new pop-up window for easier viewing.

Lighting Differences Between 1989 and 1999 Standards
Nine out of 10 commercial buildings were constructed before 1986; in most of these older buildings, lighting accounts for 50% of electrical energy use, according to the New Building Institute. In newer buildings that meet ASHRAE/IESNA 90.1-1999, lighting accounts for only 30% of electrical energy use.

To address general differences, Standard 90.1-1999 was designed to be easier to use than 90.1-1989 and is written in clearer, manda tory, enforceable language for both new construction and renovations. The code mandates the calculation procedure for fixture wattage to prevent under-calculation, and includes a much broader range of building categories to make the code usable and enforceable. The 1989 code provided single-value whole building lighting power densities for only 11 building types, while 90.1-1999 provides densities for 31 building types. In addition, a number of exemptions in the 1989 version are not present in the 1999 version, such as process facilities; the 1999 version does include a number of narrowly targeted exemptions, such as safety lighting.

Standard 90.1-1999 is largely prescriptive, setting lighting power allowances for interior and exterior applications, with interior applications addressed using either the whole building method or space-by-space method. It provides power limits for exit signs. To address special lighting needs, the code also provides specific additional allowances for decorative, merchandise, display and accent lighting, and lighting used to reduce glare on computer screens in certain spaces. For exterior applications, power allowances are prescribed for building entrances, exits and highlighting. Manda tory tandem wiring requirements are provided to reduce the use of single-lamp ballasts. The lighting power allowances are generally stricter based on advancements in commercially available lighting technologies over the last 10 years.

Regarding the whole building method, for example, office W/sq.ft. is reduced from 2.1-3.3 to 1.3; retail W/sq.ft. is reduced from 2.1-3.3 to 1.9; and school W/sq.ft. is reduced from 1.5-2.4 to 1.5. Regarding the space-by-space method, below are several examples of changes in lighting power allowances:

	Lighting Power Allowances (W/Sq.Ft.)
Space	90.1-1989	90.1-1999
Office Enclosed	1.8	1.5
Office Open	1.9	1.3
Conference	1.8	1.5
Training	2	1.6
Lobby	1.9	1.8
Lounge/Dining	2.5	1.4
Food Prep	1.4	2.2
Corridor	0.8	0.7
Restroom	0.8	1
Active Storage	1	1.1

It is assumed that light levels in these spaces will be maintained at IESNA-recommended values, which were used in development of the power allowances in Standard 90.1-1999. Compliance will require more-efficient technology, mostly more-efficient lamps and ballasts. For more sophisticated or alternative approaches, engineers can use the energy cost budget method (computer calculations) to demonstrate load reduction within code limits.

ASHRAE/IES 90.1-1999 and Lighting Controls
Standard 90.1-1999 includes broad manda tory provisions in regards to lighting controls. The 1989 code required minimum controls and covered their accessibility. Automatic controls were addressed in the form of credits for higher power allowances if occupancy sensors, lumen maintenance controls or daylight controls were included in the design.

Standard 90.1-1999 mandates that either scheduling or occupancy sensing automatic shut-off strategies be used for buildings larger than 5,000 sq.ft., the only exemption being lighting operated 24 hours/day. The control device can be:

In addition, each space that is enclosed by ceiling-high partitions must have at least one control device that independently controls the general lighting in the space. Each control device is activated either by an automatic motion sensor or manually by an occupant.

Exterior lighting not exempted in the Standard must be controlled by a photocell or astronomical timeclock.

Light fixtures that are in the same space and on the same control device, using one or three linear fluorescent lamps greater than 30W each, must use two-lamp tandem-wired ballasts in place of single-lamp ballasts.

To see Figure 2, click here. It will open in a new pop-up window for easier viewing.

California’s Title 24 energy code also mandates bi-level switching to achieve 50% energy savings, with exceptions being corridors, storerooms, restrooms, public lobbies, guestrooms, areas with only one fixture, and spaces where occupancy sensors are used. The IECC also requires bi-level switching.

Building-wide dimming is not addressed by Standard 90.1-1999, although it can be incorporated into computer calculations under the energy cost budget method to demonstrate load reduction.

“The Lighting Controls Association supports nationwide adoption of the ASHRAE/IES 90.1-1999 energy code,” says A.J. Glaser, president of the Lighting Controls Association and HUNT Dimming, a manufacturer of dimming controls. “According to the New Buildings Institute, which developed the 2001 Advanced Lighting Guidelines, lighting controls can reduce lighting energy consumption by 50% in existing buildings and at least 35% in new construction. What Standard 90.1-1999 does is acknowledge that while energy savings vary by application, the positive economic impact of advanced controls is certain. And a broad range of commercially available products and technologies are available from controls manufacturers to address all code requirements and specific opportunities.”

Pluses and Minuses
Energy codes can be viewed as a double-edged sword. On the positive side, says Weitz, a common standard makes doing business easier for design professionals who work nationwide because they will only have to know essentially one code. Adoption of a single standard is a great stride towards uniformity.

He also points out that saving energy, the ultimate goal of the code, is good for the country. “From a national policy perspective,” he says, “saving wasted energy is becoming an increasingly important issue for the nation’s economy, environment and security. There are significant savings that can be garnered from buildings, which consume 37% of our country’s total energy and 70% of our electricity.”

In addition, says Weitz, large-scale adoption of stricter energy codes increases demand for energy-efficient lighting technologies, which expands supply. “Codes can help to drive down the cost of efficient technologies by expanding markets and thereby increasing supply,” he says. “We saw this with T8 lamps and electronic ballasts, and it will apply to new technologies as they are introduced and proven in the market.”

Finally, while the lighting requirements of Standard 90.1-1999 are much stricter than the 1989 Standard, the Standard was developed with participation of lighting industry professionals, and incorporates existing technology into realistic energy-saving targets.

On the negative side, Standard 90.1-1999’s lighting requirements are about 50% more efficient than the 1989 Standard, which some lighting designers believe limits creativity by limiting design choices. Good energy does do not guarantee good lighting design, and in fact can inhibit it. Part of this criticism is that the code does not recognize high-end applications that may require a more intensive level of lighting.

Weitz is sensitive to this criticism, but essentially disagrees. “Many new buildings are being built with quality lighting designs that use even less energy than allowed by code. The writers of lighting energy codes recognize the need for flexibility in lighting design and incorporate additional lighting power allowances aimed directly at providing additional power for these purposes. It is important for designers to understand these allowances and make effective use of them. Creativity always has limits that are imposed on it—budget, time and the practical needs of the occupants can be said to ‘inhibit’ creativity.”

From another standpoint, in fact, energy codes may be said to demand greater creativity, lighting designers that can provide creative lighting solutions while complying with the code will likely be perceived as more competitive, and rewarded for it.

Weitz adds that not only is the 1999 Standard achievable, it is in fact already outdated. “The lighting power allowances in both the 2003 IECC and the forthcoming 90.1-2004 are 20-25% more efficient than Standard 90.1-1999,” he says. “Many designs going in today, for example the rapidly growing number of LEED-certified buildings, achieve high-quality interior lighting at levels even below the 2004 levels.”

Another criticism of the energy code is that the content of the code is only as good as the system for compliance. “This is indeed a problem, but it is one that is difficult to quantify,” says Weitz. “Many jurisdictions do a fine job in both plan review and inspection, but this is by no means universal. There are some jurisdictions, in fact, which simply do not perform inspections themselves, but leave that function up to the designer of record.”

Taking It Further
To help designers exceed Standard 90.1-1999’s requirements by 30-50% and thereby achieve LEED certification for sustainable building design, ASHRAE is developing a series of Advanced Energy Design Guides.

As stated, the savings will help designers achieve Leadership in Energy and Environmental Design (LEED) certification, offered by the U.S. Green Building Council (USGBC), with which ASHRAE has a partnership agreement.

"LEED gives 'points' for achieving different levels of energy savings over Standard 90,” says Terry Townsend, ASHRAE’s representative on an ASHRAE/ USGBC steering committee. “However, the LEED program does not tell designers how to achieve these savings—instead it is left to their discretion. With the ASHRAE guides and proposed educational programs, designers will be told what to do and how to do it."

The Guides will consist of a series of documents applying to education facilities (both kindergarten through 12th grade and colleges and universities), food sales and service, healthcare facilities, lodging, mercantile, mixed use facilities, public assembly/religious worship facilities, residential (single family, low-rise multifamily and high-rise multifamily) and offices.

The first document in the 30% series will provide prescriptive design assistance for office buildings up to 20,000 sq.ft. It will be a how-to, user-friendly guide targeted for use by contractors and small design-build firms, according to Townsend.

ASHRAE also is continuing work on guidance to achieve 50 percent savings. As with the 30% guides, this series will be developed for commercial, industrial, institutional and residential applications. The 50% documents would be published in two to three years. Guides for achieving 75% will follow.

ASHRAE’s educational program is targeting designers, with a parallel effort by the AIA for architects and owners.