Appliance Standards Upgraded January 23

By Arlene Stewart

This Q&A-formatted article is designed to alert builders to the new federal law that will affect the energy efficient standards of their appliances.

What is this NAECA change? The National Appliance Energy Conservation Act (NAECA) is a federal law that requires the US Department of Energy (DOE) to set minimum appliance energy efficiency standards, which include standards for HVAC systems. In 2001, DOE increased the standard to SEER 13 for air conditioners and HSPF 7.7 for heat pumps, to take effect on January 23, 2006.

How many homes in Florida will NAECA affect? According to a Florida Home Builder Association (FHBA) analysis, approximately 60% or 130,000 housing starts will be affected by this change.

If NAECA is a manufacturing act, why does it affect the building codes? NAECA has a number of different provisions, one of which preempts (overrules) state and local building codes that use HVAC efficiencies other than the federal minimums. This provision was included to protect HVAC manufacturers from being required to meet different standards in different states and to ensure that the increased efficiency levels mandated by federal law were actually being achieved and not offset by other reductions in energy efficiency. On December 20, 2005, the US Department of Energy (DOE) provided guidance on this provision at http://www.energycodes.gov/residential_ac_hp.stm. In short, the state minimums (baseline) on which the energy code is based were legally required to be changed on January 23, 2006 as a result of the federal minimum change. DOE recommends that states incorporate the NAECA change into the building code as soon as possible. It also states that SEER 10 equipment can be used until existing stock is used up, but that trade-offs not be allowed.

Does this mean SEER 10 units are illegal? No, but only for the 35% of the housing starts that currently use SEER 10 equipment. Higher efficiency HVAC units should not be used to trade-off against other efficiency measures unless and until the baseline in the analysis is set at the new level. However, for the more than 60% of housing starts that use better than minimum equipment in a performance calculation, this transition can be confusing. (See next question.)

NAECA is only about air-conditioning, right? No. Because of the federal preemption, increasing the minimum HVAC will cause an overall increase in home efficiency of about 10-20% depending on where in Florida you live. Builders in Florida regularly trade off building envelope performance against HVAC efficiency. For example, prior to January 23, 2006, a builder could install a SEER 12 unit to use less efficient windows or wall insulation. This is no longer an option. To keep the same package (with traded-off building envelope measures), builders will have to do two HVAC increases. The first will be to SEER 13, which will be the new baseline as required by federal law. The second will be to SEER 16 to keep the increment increase of HVAC efficiency in the same house configuration. Product research indicates that the incremental cost of products above a SEER 13 runs about $1000- $3000. Thermal envelope measures, like returning to the original baseline wall or window products, will gain more popularity, since they will now be more cost effective and will improve the housing stock statewide over the long term. And yes, it does seem strange that SEER 10 may still be used, but that higher SEER equipment has to be used if a SEER 11 or 12 was used before January 23, 2005.

What other building components might be affected? In years past, windows, walls and slab efficiency have all been reduced as trade-offs in favor of higher HVAC efficiency or other measures (such as locating air handler in conditioned space, adding ceiling fans, programmable thermostats, etc.). Now builders will probably consider bringing the efficiency back up to the following original FEC baseline levels because of the expense and availability of higher efficiency HVAC equipment.

Isn't it easier to just use higher SEER equipment? It might be if these units can be obtained. However, realize the shift to the SEER 13 can be an installation challenge for HVAC contractors and even higher SEER equipment are even more challenging. Moreover, the HVAC industry may not be able to provide the volume of higher SEER equipment Florida needs and there might not be as many product options that can provide adequate moisture removal in those higher SEER units for Florida’s humid climate (at least 0.70 sensible heat ratio (SHR) or lower). HVAC manufacturers are probably more focused on making the transition from 10 to 13 than on volume sales of higher SEER equipment. Certainly a cost increase of $1000-$3000 may also discourage the higher SEER choice and it is unknown how utility rebates will change. Many would argue that moving closer to the baseline envelope will provide significant benefits to Florida builders and homeowners, particularly given today's extraordinarily high cost of energy. So, while higher SEER might seem easy initially, better envelope measures are likely to be more cost-effective and would produce more comfortable, better performing homes without major changes in construction practices.

How many homes will the NAECA change affect? An analysis done for the FHBA showed that only 1% of single-family homes will meet the new requirements without any changes. 36% of homes would just need to upgrade from SEER 10/HSPF6.8 to SEER 13/HSPF 7.7 mechanical equipment, while 63% of homes will require other measures to meet the requirements because they already use SEER 11, 12, and 13 HVAC.

When will Florida officially make the switch? The US Department of Energy is encouraging states to incorporate this provision as close to the January 23 implementation date as possible. Some observers have suggested that the legal effect of the federal preemption is that the change has already effectively occurred, creating a risk to those who are not complying today. From an administrative perspective, Florida is presently moving through its code change process to adopt changes to effectuate this federal requirement. Most likely, it will be implemented in November 2006 with the regular building code cycle.

Will NAECA require NFRC certification for windows? NFRC testing is already required in Florida for any window claiming thermal performance better than the worst case. Baseline (or close to baseline) windows will need to prove compliance with NFRC 100 and 200 because they provide much better energy code credit than the window defaults that do not require testing. Full NFRC certification is arguably the best way to provide such proof, but FEC language allows manufacturers to self-certify. However, building officials do have the right to expect that manufacturers provide test reports from accredited labs to prove performance claims.

Will single pane windows be illegal? They would not be illegal, but it would be very difficult to find one that could comply cost-effectively throughout the home, other than low E or tinted monolithic impact windows (see next question). Most often, low-E windows need to be protected from construction damage and the weather. Therefore, most low-E coatings are used in insulated glass units or monolithic impact windows. Some heavy architectural tints can also meet the 0.4 SHGC baseline, but may not appeal to homeowners.

Will glass block be illegal? No. Florida still has a predominantly performance-based code. While glass block doesn’t quite hit 0.4 SHGC baseline, they can get close. Chances are that other efficiency measures would offset the small difference in energy efficiency in a relatively small part of the wall system.

Will NAECA prohibit monolithic impact windows? No. Fenestration Manufacturers Association (FMA) representatives spoke with manufacturers and reviewed test protocols to see how monolithic impact windows would be affected. Initial reports indicated that there were several manufacturers who could reach a 0.5 SHGC, though some require heavy tinting to do so. Again, since Florida has a predominantly performance-based code, the improved solar control, though not as good as baseline, would have a significant impact on improving energy efficiency. Moreover, it is expected that the Florida Building Commission will accept the recommendation to shift the U-factor baseline from 0.5 U-factor to 0.75 U-factor, which is consistent with the International Energy Conservation Code.

Will double furring be required on concrete walls? The mass wall baseline equivalent is R-6, so it is likely that builders will consider R-6 and double furring because of the SEER 13 double jump mentioned above.

Sources of information for this article included energycodes.gov; Brickfield, Burchette, Ritts & Stone; Florida Department of Community Affairs; National Association of Home Builders (NAHB); Florida Building Code-Chapter 13, Federal Register; and the official DCA energy code database from the Shimberg Center for Affordable Housing.

Arlene Z. Stewart is the FHBA Area II Associate Vice President and owner of AZS Consulting in Gainesville.

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