The buildings sector accounts for about 76% of electricity use and 40% of all U.S. primary energy use and associated greenhouse gas emissions, making it essential to reduce energy consumption in buildings in order to meet national energy and environmental challenges and to reduce costs to building owners and tenants. Opportunities for improved efficiency are enormous.
This guide explores California’s Title 24 Building Energy Efficiency Standards as the perfect example of how these opportunities could be realized.
Readers can expect to learn:
- How much Title 24 is expected to save consumers over the coming decades
- When Title 24 is and is not required
- Why Title 24 is relevant to NEBB professionals
What is Title 24?
When zooming in to look at how California is pioneering energy efficiency requirements at the state level, the Title 24 Building Energy Efficiency Standards take center stage. Title 24 exists to regulate California’s Energy Efficiency Standards for residential and nonresidential buildings. According to the California Energy Commission (CEC) website, California’s energy code is designed to reduce wasteful and unnecessary energy consumption in newly constructed and existing buildings.
While Title 24 includes 12 different parts in its entirety, it is Part 6 which regulates building energy efficiency in newly constructed projects, additions and alterations of both residential and nonresidential buildings. Title 24, Part 6 is updated every three years, with subsequent revisions focused on building on efficiency goals and implementing new technologies or processes as they apply.
“The intention of Title 24 is to help uncover energy inefficiencies where energy grid usage is more than it needs to be,” explains Curtis Worley, EVP of Pacific Test and Balance, Inc. “Part 6 is the portion that applies to NEBB.”
How Have Title 24 Requirements Changed Since Their Introduction?
California’s Title 24 was initially enacted in 1978 as a means of unifying all building standards under a single code to help ease the process for architects, engineers, and contractors. By 1988, Title 24 applied to all occupancies in the State of California.
Although Title 24 requirements are nothing new, some notable changes have been in the works for nearly a decade. Since the enforcement of the 2005 Building Energy Efficiency Standards, technicians have been required to perform acceptance testing for non-residential buildings. Technicians have had the opportunity to become trained and certified in performing and documenting acceptance testing for lighting controls and mechanical systems for non-residential buildings since 2013.
At a meeting held on April 14, 2021, the California Energy Commission unanimously approved the requirement for using certified acceptance test technicians for Title 24 Acceptance tests to be performed statewide after October 1, 2021. This means the Acceptance Test Technician (ATT) must be certified by a certification provider. The Certified ATT is responsible for performing testing for HVAC systems and controls when the mechanical equipment is required to meet specific energy efficient processes.
“For example, a five-ton packaged AC unit may now need an economizer, depending on the climate, in order to meet requirements,” states Amber Kelly, TAB Superintendent at ACCO Engineered Systems.
If non-certified forms are submitted, they will not be accepted and will likely hold up the permitting process, causing project delays. Contractors that cannot submit certified forms and are found to be holding up the Temporary Certificate of Occupancy can also face costly contract fees.
“The nuts and bolts haven’t been changed. The difference is that, before, CEC inspectors received handwritten forms with no proof of competency; now those people need to be certified. Acceptance forms were not being performed properly or at all, which even resulted in some falsified documents previously,” relays Worley.
Holding some of the same responsibilities as a county inspector, an ATT is classified as an inspector and is required to prove systems operate as intended and comply with energy efficiency requirements. Now, an ATT can be held under federal penalty of perjury if tests are falsified.
When is Title 24 Not Required?
Title 24 regulations apply to the construction of any new residential or nonresidential building in California. But there are a handful of partial exceptions to the requirements, including:
- Temporary buildings: Structures erected for temporary purposes, such as fairs and festivals, are typically except from Title 24.
- History landmarks: Buildings designated as historic landmarks are exempt from Title 24, but only if compliance would change the building’s historical characteristics.
- Existing energy-efficient features: Buildings that have already been insulated or had energy-efficient lighting can be exempt from certain aspects of Title 24.
How is Title 24 Relevant to NEBB?
In order to pursue certification, a technician must first select one of the certification providers approved by the State of California. Currently, the certifying bodies include NEBB, Refrigeration Service Engineers Society (RSES), National Energy Management Institute Committee (NEMIC), and the California State Pipe Trades Council (CalPipe). The process of ATT certification and forms that will be taught depend on the certification provider. However, it’s worth noting there is a written as well as hands-on component to all certification processes.
“You’re taught how to fill out the forms and what to look for on the job. If you’ve been doing it right all along, there should be no surprises. Any technician working in HVAC will have no problem. If anything, it helps weed out the bad contractors,” affirms Kelly. “In years past, it was not unheard of to find thermostats programmed incorrectly or economizers not plugged in at all previously. This is California’s way of ensuring the systems do work right from the beginning and that there’s enough ventilation in your building.”
“These new changes ensure competency, as well as serve as gatekeepers in getting a Temporary Certificate of Occupancy or Certificate of Occupancy,” expresses Worley. Once an employer is certified and has a Certified ATT on staff, they may perform Title 24 testing for the forms in which they are certified. This can translate to greater opportunities and potential work.
An ATT goes through technician certification, while a Certified Acceptance Test Employer (ATE) is a company that states it will handle the records to ensure work is performed by certified individuals. By certifying technicians, NEBB is responsible for testing and quality control and dealing with any complaints.
NEBB’s ATT Certification Process
There are 19 different acceptance tests that can be required through Title 24 depending on one’s job function. However, not many technicians deal with all 19 of those tests. It’s understandable that a technician may not want to give up the time and resources required to study all the associated forms for testing they will never perform.
With that in mind, NEBB has grouped some of the most popular testing combinations in packages. The packages were created to accommodate the different ways professionals work with Title 24 and what forms they use most to prevent having to learn or pay for unnecessary forms. For example, one is for packaged units, one is for water systems, another for controls, and so on. NEBB’s ATT packages can be viewed at: https://nebb.org/technician-certification/.
While some trade associations may pay for members to become certified, the process can be a lengthy one when other certification providers require technicians to become certified in all 19 forms. Because NEBB allows technicians to select specific forms to be certified in, the amount of time to train is fairly short. Once certified, NEBB grants the ATT access to the selected forms.
“The process is way faster than the other organizations,” Kelly suggests. “Through NEBB, technicians take an online test to prove experience, then an online course specific to that form, then hands-on at Brownson Technical School in SoCal, pay your fee, take the test, and you’re certified!”
NEBB also has reciprocity written into its program. “That means if you’re certified via NEMIC, RSCS, or CalPipe, you can apply and bypass training to be certified via NEBB’s program,” states Kelly. “That way, you can use any and all of the registries you’re certified in. If using NEBB, it helps to simplify things because we can then do everything in one place.”
How are Title 24 Changes Affecting the Industry?
Due to the length of the construction cycle typically taking between six months to two years, projects already permitted, are not required to go through the new Title 24 process. Compliance with Title 24 began with any projects that required permitting after October 1st of last year.
“That is one of the reasons we’re not seeing Title 24 in full effect at the moment. However, we expect new buildings will increase the number of projects working to meet Title 24 compliance in time,” states Worley.
Although Title 24 is part of the state’s energy code, it is enforced by local jurisdictions. Different cities and counties have taken different pathways to enforcement. Many inspectors and building officials are not trained yet, so the process is not being followed everywhere.
“Metropolitan areas like San Francisco and Los Angeles were some of the first the embrace Title 24. In San Francisco alone, thousands of forms have been turned in on projects. However, some other areas seem to be taking a wait and see approach,” Worley describes. “The state has lacked training and enforcements of it, but people are starting to pay more attention. We’ve been talking about this since the 2013 code cycle,” clarifies Kelly. “Still, some are taking a ‘we’ll do it when we have to’ approach. But others, like ACCO, have been proactive about certifying people.”
In the coming months, NEBB’s Title 24 Committee plans to offer continuing education credits to inspectors through the NEBB Learning Center. Both Kelly and Worley serve on NEBB’s Title 24 Committee. Through an online course, they aim to explain what inspectors should be looking for to help provide training.
Why Should Contractors Outside California Care?
Title 24 requirements are expected to produce $1.5 billion in consumer benefits and reduce 10 million metric tons of greenhouse gases over the next 3 decades. These efforts not only save costs for building owners in terms of lower utility usage, but can also free up space on the grid for other initiatives and accommodate population growth.
“Efficiency savings can be used to power up vehicles and power up the grid. For example, if we can increase efficiencies by ten percent, we have the potential to offset the costs of going to all electric vehicles,” states Worley. “We need capacity across the system. There’s a limitation to what can be produced and provided via the current infrastructure.”
“Title 24 isn’t about making it work. It’s about proving that it does,” declares Kelly. “It ensures occupancy safety and with outdoor air requirements, and ensures people have enough fresh air indoors.”
Presently, most states look to ANSI/ASHRAE/IES Standard 90.1 for guidance on ventilation and energy efficiency in commercial buildings. States such as Florida, Iowa, New York, and Virginia use this standard via International Energy Conservation Code (IECC) as a commercial energy code, while others like Alabama, Indiana, Louisiana, Mississippi, New Jersey, Oregon, and West Virginia have adopted it directly.
Because California often serves as a pilot program for the rest of the United States, out-of-state contractors may want to keep an ear to the ground. As we’ve seen in the past, what happens in California is often mirrored by other states over the next decade. Some say California is the guinea pig, yet others believe the state is just ahead of the curve. Either way, this can be a very beneficial thing for other states that can use California’s “pilot” projects for lessons learned in order to streamline, refine, and tailor to their own efficiency efforts.
“Title 24 helps to monitor the energy efficiency of HVAC equipment in California. It’s currently not a program in other states, but if it goes smoothly, that is a likely result,” states Kelly.
“Although it is a state mandate now, it could be become federally mandated in the future,” agrees Worley. Another great reason to pay attention is to capitalize on business opportunities. There are opportunities related to both Title 24 Acceptance Testing work, as well as commissioning.
“It’s a business opportunity for those outside of California that want to get certified and come out just to do the Title 24 portion of the job. There’s a market for that now that it’s required,” depicts Kelly. “And because it’s pass/fail, if it fails, you can get paid to come back.”
In terms of commissioning, some people have been portraying Title 24 compliance as a type of step-by-step commissioning. “It does not take the place of commissioning at all because commissioning is broader picture with more details,” explains Kelly. If anything, this is actually an opportunity for third-party commissioning agents because commissioning is required for projects of a certain size and complexity.
For more information on how to take advantage of these opportunities and become certified, visit NEBB’s website at www.nebb.org.
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