Get Full Government Meeting Transcripts, Videos, & Alerts Forever!
Get email alerts on the R405 Reference Design Renewables topic
No spam. Unsubscribe anytime.
Board debates whether adding renewables and efficient appliances to the reference design creates a loophole
Summary
Board members debated proposed rows in the R405 standard reference design that would credit on‑site renewables and efficient non‑HVAC appliances. Some opposed the rows as enabling envelope trade‑offs; others said R405 already requires more stringent envelopes and changes can be aligned with R408.
Board members discussed whether new rows added to the standard reference design table for R405 (whole‑building simulated performance) could unintentionally allow projects to weaken building envelopes while claiming savings for on‑site renewables and efficient appliances.
The issue was raised after public comment from the Responsible Energy Code Alliance and others. Jess (board member) asked whether the table additions for "renewable energy, lighting, and non‑HVAC appliances" could create a loophole that permitted lower envelope efficiency in exchange for credits from renewables or appliance efficiency.
Several board members, including Kevin and Tim, supported removing the new rows; Kevin said the change risked incentivizing poorer envelope performance. Others, including Elizabeth and Christian, said R405 already includes an envelope backstop: the modeled building must achieve an envelope that is roughly 15% better than the prescriptive baseline, so R405 tends to be a more stringent compliance path and does not offer a "get out of jail free" option. Elizabeth noted that if the board removes renewables from R405 the same allowances would still be available through the ERI/prescriptive path (R408) unless explicitly changed there.
Kim (staff) and others reminded the board that several members had already submitted proposals to adjust the standard reference design and that those proposed changes would be discussed in upcoming proposal sessions. The board did not take a final vote on R405 table rows at this meeting; multiple members said they preferred to resolve the language in the proposal phase after additional technical review.
Board direction: staff to fold the discussion into the proposal deliberations for R405 and R408 and to ensure any changes are aligned across pathways so they do not permit unintended tradeoffs.
