Join energy code public hearing

February 21, 2022

The Washington State Energy Code has a public hearing Friday, Feb. 25 at 10 a.m. To sign up for oral testimony, please complete the Public Testimony Sign Up Sheet.

Proposals Applicable to Multi-Family Construction

C402.5.3 – Building thermal envelope testing

Stance: Opposed

Reasoning: Air leakage rate now must not exceed 0.25 cfm per square foot rate. This adds cost to the construction of multi-family buildings.

According to Department of Energy, costs could be as high as:

• $600 per project ($0.12 per square foot) – 5,000 & below square feet
• $25,000 per project ($0.50 per square foot) – 5,000-50,000 square feet
• $15,000 per project ($0.15 per square foot) – 50,000-100,000 square feet

C403.1.1 and Appendix D – Space Heating Proposal

Stance: Opposed

Reasoning: Requires heat pump space heating rather than fossil fuel or electric space heating for all buildings without regard for electric grid reliability, consumer preference and lifespan/reliability/payback period of heat pump space heating units. Heat pumps are generally more expensive to purchase and install, as well as maintain, compared to other heating options.

 

C404.2.1, C404.7, C503.59 – Heat pump water heating

Stance: Opposed

Reasoning: Requires heat pump water heating rather than fossil fuel water heating for all buildings without regard for electric grid reliability, consumer preference and lifespan/reliability/payback period of heat pump water heating units, often more expensive to install and maintain than their water heating counterparts.

 

C405.7.1 – Electrical Receptacles at gas appliances

Stance: Opposed

Reasoning: $250 added per receptacle installed, with added cost for additional electrical panel upgrades to ensure the ability to maintain electrical load demand. If utility-side upgrades are required, it can easily be in excess of $20,000.

 

C406 – Additional Efficiency

Stance: Opposed

Reasoning: Increases the number of energy-efficient credits required to be compliant. Depending on the credits selected, this could increase the cost of constructing multi-family buildings which will increase rents paid by future tenants.

 

C406 – Options Added to Credits: Heat pump dryers and low-flow showerheads

Stance: Opposed

Reasoning: Heat pump dryers are double the cost of a traditional dryer. Low-flow showerheads are known for delivering cooler water and have a slower rate of response to changing the temperature of the water when showering. These showerheads also deliver lower water pressure which saves water but won’t necessarily save on energy usage if the person showering has to spend more time in the shower.

 

C407 – Total building performance 

Stance: Support

Reasoning: Provides flexibility to developers in meeting construction requirements under the new iteration of the Commercial Energy Code.

 

C411 – Renewable energy

Stance: Opposed

Reasoning: Requires on-site renewable energy generation for buildings over 10,000 square feet of gross conditioned floor area. Any costs added to the construction of the multi-family building will be passed onto the future renter in rental premiums.

If you have any questions about the Washington State Energy Codes and requirements, please contact Building Codes and Policy Manager Andrea Smith at (360) 352-7800 ext. 114 or at andreas@biaw.com.