Proposed Modification to the Florida Building Code

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					Proposed Modification to the Florida Building Code
Modification #: Name: Section 553.73, Fla Stat

Jeff Householder for the Florida Propane Gas Association (FPGA) and Florida Natural Gas Association (FNGA) (David Rogers, Executive Vice President, FPGA; Executive Director FNGA) 214 S. Monroe Street, Tallahassee, FL, 32301 jmhouseholder@aol.com or david@floridagas.org 850-681-0496 850-222-7892 Florida Building Code 2004 – Chapter 13 Florida Energy Efficiency for Building Construction Section 13-608 Space Heating Systems and Section 13-612 Water Heating Systems

Address: E-mail: Phone: Fax: Code: Section #:

Text of Modification [additions underlined; deletions stricken]: Proposed Energy Code Method A Heating and Water Heating Multiplier revisions for combustion fuel appliances. 1) Modify Appendix 13-D, Form 600A North 123, Central 456 and South 789, Table 6A-18 Heating System Multipliers (HSM) as follows:
6A-18 Heating System Multipliers (HSM) All Climate Zones SYSTEM TYPE see Table 13-607.1.ABC.3.2 B,D 13-608.1.ABC.3.2 E,F for code minimums HSPF 7.4-7.6 .46 9.9-10.3 .34 2.50-2.69 .40 3.70-3.89 .27 .76-.77 .46 .93 - .95 .34 7.7-7.8 .44 10.4-10.8 .33 2.70-2.89 .37 3.90-4.19 .26 .78 .44 .96 - .98 .33 .79 - .82 .43 .99 - 1.00 .31 .83 - .85 .41 .86 - .89 .38 .90 - .92 .36 7.9-8.3 .43 10.9-11.3 .31 2.90-3.09 .34 8.4-8.8 .41 11.4-11.8 .30 3.10-3.29 .32 8.9-9.3 .38 11.9-12.3 .29 3.30-3.49 .30 9.4-9.8 .36 12.4&up .28 3.50-3.69 .29 Heating System Multipliers (HSM)

Central Heat Pump Units

HSM HSPF HSM COP HSM COP HSM AFUE HSM AFUE HSM

PTHP

Gas Heating

Electric Strip and Gas

1.0 (for gas credit multipliers, see Table 6A-21)

2) Modify the first sentence in Section 608.2.A.3 Heating Credit Multipliers to read: Heating credit multipliers (HCM) are given for certain technologies which reduce energy use or cost.
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3) Delete Section 13.608.2.A.3.3 Natural Gas Furnaces in its entirety.

4) Delete Section 13.608.2.A.3.4 LP-gas in its entirety.

5) Modify Appendix 13-D, Form 600A North 123, Central 456 and South 789, Table 6A-21 Heating Credit Multipliers (HCM) to delete the existing Natural Gas and Propane Gas Multiplier categories.
6A-18 Heating System Multipliers (HSM) Climate Zones 1 2 3

6A-18 Heating System Multipliers (HSM) Climate Zones 4 5 6

6A-18 Heating System Multipliers (HSM) Climate Zones 7 8 9

6) Modify Appendix 13-D, Form 600A-04 North 123, Central 456 and South 789, Table 6A-22 Hot Water Multipliers (HWM) to add a new Gas Water Heater category with multipliers. No change is proposed for the Electric Resistance or Dedicated Heat Pump / Solar System category.
6A-22 Hot Water Multipliers (HWM) Climate Zones 1 2 3 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code minimums Hot Water Multipliers (HWM) Electric Resistance EF HWM EF Gas Water Heating HWM EF HWM .80 - .81 3020 .54 3020 .62 -.63 2346 .82 - .83 2946 .55 2946 .64 - .65 2217 .84 - .85 2876 .56 2876 .66 - .70 2101 .86 - .87 2809 .57 2809 .71 - .75 1738 .88 - .90 2746 .58 2746 .76 - .80 1456 .91 - .93 2655 .59 2655 .81 - .83 1196 .94 - .96 2571 .60 2571 .84 - .86 1055 .97 & Up 2491 .61 2491 .87 & Up 933

6A-22 Hot Water Multipliers (HWM) Climate Zones 4 5 6 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code minimums Electric Resistance EF HWM .80 - .81 2820 .82 - .83 2752

Hot Water Multipliers (HWM) .84 - .85 2685 .86 - .87 2624 .88 - .90 2564 .91 - .93 2479 .94 - .96 2400 .97 & Up 2326

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EF Gas Water Heating HWM EF HWM

.54 2820 .62 -.63 2191

.55 2752 .64 - .65 2070

.56 2685 .66 - .70 1962

.57 2624 .71 - .75 1623

.58 2564 .76 - .80 1359

.59 2479 .81 - .83 1117

.60 2400 .84 - .86 985

.61 2326 .87 & Up 871

6A-22 Hot Water Multipliers (HWM) Climate Zones 7 8 9 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code minimums Hot Water Multipliers (HWM) Electric Resistance EF HWM EF Gas Water Heating HWM EF HWM .80 - .81 2606 .54 2606 .62 -.63 2024 .82 - .83 2543 .55 2543 .64 - .65 1912 .84 - .85 2482 .56 2482 .66 - .70 1813 .86 - .87 2424 .57 2424 .71 - .75 1500 .88 - .90 2369 .58 2369 .76 - .80 1256 .91 - .93 2290 .59 2290 .81 - .83 1032 .94 - .96 2218 .60 2218 .84 - .86 910 .97 & Up 2149 .61 2149 .87 & Up 805

7) Modify Appendix 13-D, Form 600A North 123, Central 456 and South 789, Table 6A-22 Hot Water Multipliers (HWM) to delete the existing Natural Gas and Propane Gas Multiplier categories and multipliers.
6A-22 Hot Water Multipliers (HWM) Climate Zones 1,2,3 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code Hot Water Multipliers (HWM) minimums

6A-22 Hot Water Multipliers (HWM) Climate Zones 4 5 6 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code Hot Water Multipliers (HWM) minimums

6A-22 Hot Water Multipliers (HWM) Climate Zones 7 8 9 SYSTEM TYPE see Table 13-612.1.ABC.3.2 for code Hot Water Multipliers (HWM) minimums

8) Modify the FLA/RES-04 computer program referenced in Section 13-600.3 Certification of Compliance, to incorporate the HCM and HWM included in this proposed code modification.
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9) Utilize the proposed HCM and HWM to establish equipment eligibility by fuel type in the Component Prescriptive Method Packages (Method B) in Appendix 13-D, Form 600B North 123, Central 456 and South 789, in conjunction with the FBC update of Method B packages to adopt the Federal 13.0 SEER and 7.7 HSPF baseline standards. 10) Modify Section 13-612.1.B.2 Gas and Oil Water Heating to read: Houses with gas and oil water heating systems installed shall met the following efficiencies to comply by any compliance package in Method B: Energy Factor = 0.59 or greater. Fiscal Impact Statement [Provide documentation of the costs and benefits of the proposed modifications to the code for each of the following entities. Cost data should be accompanied by a list of assumptions and supporting documentation. Explain expected benefits.]: A. Impact to local entity relative to enforcement of code: There are no known adverse cost impacts to local code enforcement agencies related to the adoption of the proposed calculation multipliers. Impact to building and property owners relative to cost of compliance with code: There are no known adverse cost impacts to building or property owners related to the adoption of the proposed calculation multipliers. The proposed methodology is a step toward the equipment fuel type compliance concept used in the national home energy rating systems. The proposed methodology provides a reasonable treatment of competing fuel types, ensures that the Energy Code baseline reflects the NEACA minimum efficiency standards, and does not degrade the overall stringency of the code. Building owners would have the opportunity to select from the full range of NAECA complying HVAC and water heating equipment of all fuel types without incurring a compliance penalty. Impact to industry relative to cost of compliance with code: There are no known adverse cost impacts to the gas, electric or homebuilding industries related to the adoption of the proposed calculation multipliers. This proposal does not change the Florida baseline home or the overall code compliance stringency.

B.

C.

Rationale [Provide an explanation of why you would like this Proposed Modification to the Florida Building Code.]: The intent of this proposed code modification is to adopt a transitional methodology for determining space heating and water heating system calculation multipliers for use in the Florida Energy Code Method A compliance computation that eliminates fuel cost as a factor in deriving the multipliers. Additionally, we are proposing the use of such multipliers in the restructuring of Method B compliance packages to accommodate the elevated Federal HVAC minimum efficiency standards. The proposed transitional methodology would better
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position the Florida code to migrate to a more sophisticated whole building simulated energy performance analysis method. Such a method would require a computerized computational software tool that would replace the existing FlaRes program and eliminate the use of calculation multipliers as applied in the current Method A compliance approach. The Florida gas industry favors adopting standards and an analysis process similar to that used in the national Home Energy Rating System (HERS). We also would recommend adoption of a standard reference design (minimum envelop and HVAC requirements) for residences compatible with to that used in the International Energy Conservation Code (IECC), with the exception that a normalized modified loads method be adopted for addressing equipment fuel type differences as currently utilized in the national home energy rating standards. It should be noted that the gas industry is not advocating wholesale adoption of the IECC Simulated Performance Alternative compliance approach that analyzes energy costs rather than energy use. In our view the normalized modified loads method, adopted in the national home energy rating standards and recommended by DOE is more appropriate. The Florida gas industry is formally proposing adoption of the normalized modified loads methodology In a separate code modification submitted to the FBC. In the event the FBC does not choose to restructure the Energy Code as described above, the gas industry’s proposed code modification would at least begin to resolve a significant area of divergence between Florida’s code and the primary national rating methods. This proposal seeks to establish baseline performance multipliers in Method A for gas-fired and electric space heating and water heating systems consistent with the National Appliance Energy Conservation Act minimum efficiency standards as promulgated by DOE in 10 CFR 430.32, Energy and Water Conservation Standards and Effective Dates. The Florida Energy Code calculation multipliers for the minimum NAECA complying gas equipment and electric equipment would be identical. Improvements in equipment efficiency regardless of fuel type would reduce (improve) the calculation multipliers based on the percentage improvement achieved through the rated efficiency of the selected unit. Gas units would be compared to gas units and electric units to electric units. While this proposal is not an optimal solution to the fuel type issue, it is a reasonable first step. The existing Method A calculation multipliers for water heating and space heating systems were developed in the mid 1990’s. The current multipliers attempt to account for both the rated efficiency and the fuel cost related to operating the selected appliance. The existing methodology was developed with good intentions. However, the fuel markets are complex and ever changing. The cost relationships between fuels change frequently. Price variations occur between suppliers, in different locations throughout the state and in different seasons of the year. The influence of geopolitical, weather and other events on the fuel markets is substantial. The impact of the recent hurricanes on oil and gas prices has had an enormous effect on customers of propane retailers, natural gas distributors and electric utilities. It is virtually impossible develop cost factors that appropriately and accurately depict price relationships between fuel types. By setting the baseline compliance multipliers for all fuel types at the same level, the existing outdated fuel cost relationships would be eliminated. The natural gas
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industry would lose some of the compliance advantage it currently has relative to electric appliance. The propane industry would achieve code compliance comparability to other fuel types. No fuel type would enjoy a compliance advantage at the baseline minimum NAECA efficiency requirements. Moving to the proposed methodology would better position the Florida Energy Code for alignment with IECC standards, national home energy rating systems, tax credit compliance determinations, energy efficient mortgage rating criteria and other emerging energy rating requirements. One of the significant differences between Florida’s code and other energy rating methods is the treatment of appliance fuel types. While the adoption of the proposed multipliers would not put Florida in sync with the above rating standards, they represent a substantial first step. As noted above, the Florida gas industry would have no objection to the adoption of a general code compliance methodology that eliminated the use of “calculation multipliers” as currently applied in the Florida Energy Code and migrated to a more robust energy performance simulation program. Several existing computer software systems are capable of producing detailed hourly energy simulation analyses that could be used for compliance purposes. The Florida Solar Energy Center has developed the EnergyGauge USA software program (using DOE 2.1 E) that could be adapted for use as the approved Florida Energy Code computational model, replacing the current FlaRes software. It is our understanding that the EnergyGauge USA software, if used as the code compliance calculation software, can be adapted to operate under the current code baseline criteria, be updated to the IECC baseline or incorporate the national home energy rating standards. In the event the FBC elected to adopt a methodological compliance process such as that incorporated in the 2006 national home energy rating standards, inclusive of the normalize modified loads method, the gas industry would withdraw this proposed code modification. In the absence of an energy source based methodology, the Florida gas industry supports the adoption of the normalized modified loads method. Based on discussions with FSEC, the EnergyGauge USA software, with minor modification, could be utilized to achieve results similar to those that would be obtained with the calculation multipliers included in this proposed code modification under the existing Energy Code compliance standards, or alternately used to produce a normalized modified loads analysis. Please explain how the proposed modification meets the following requirements: 1. Has a reasonable and substantial connection with the health, safety, and welfare of the general public: The proposed calculations multipliers eliminates the use of out of date fuel factors in the determination of heating system calculation multipliers. Assigning multipliers based on energy use at the rated efficiency of a selected appliance provides a more fundamentally sound basis for energy performance results that may affect consumer appliance choices. Strengthens or improves the code, and provides equivalent or better products, methods, or systems of construction: The proposed calculation multipliers positions the Florida Energy code to ultimately gain compatibility with the national home energy rating systems, IECC baseline standards and tax credit certification requirements under the Energy policy Act of 2005.
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2.

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3.

Does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities: Adoption of the proposed multipliers would not discriminate against any product or system. Only the combustion system multipliers are affected. Establishing equivalent multipliers for competing fuel types at the NAECA minimum efficiency levels ensures that no fuel type gains an unwarranted advantage. Does not degrade the effectiveness of the code: Use of the proposed multipliers would not materially affect the baseline standards or stringency of the code.

4.

Section for DCA Only
Committee Action: Committee Reason: Commission Action: Commission Reason:

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