Plato once stated, “Silence is Consent.”
Currently the Environmental Protection Agency (EPA) is updating their criteria for Rev. 05 of the ENERGY STAR Multifamily New Construction Program (MFNC). You can review the list of changes here. While the scope of these changes with respect to multifamily are many, EPA is focusing on seven areas for multifamily that they are looking for feedback from the experts in are industry (you):
- Limit townhouse eligibility to single-family new homes
- Require MFNC Workbook for all buildings
- Streamline insulation and reduced thermal bridging details
- Transition to Track A: HVAC Grading by Rater and Sunset Track B
- Streamline mandatory lighting requirements
- Consolidate ASHRAE Path Performance Target & documentation; add fuel neutral approach
- Transition to whole-building modeling path in California
We are currently in the feedback period for these changes. They are looking for your thoughts around the following topics:
- Do you agree with a building-level 10% performance target for CA v1.2 and v1.3?
- Are any multifamily dwelling units modeled separately for code under Title 24 2016 or 2019?
- Is the 10% target for common spaces when modeled separately reasonable?
- Do you have any additional feedback on this proposal?
If you have any feedback, now is the time to speak up and share it with EPA. Having recently attended an online seminar reviewing these changes, I appreciated that the EPA presenter recognized how complicated multifamily construction can be as there are so many variants in the construction process with respect to heating and cooling within the units and within the common area spaces. In a nutshell, they are recognizing you as the expert and they want your feedback.
The Resources and Feedback form from EPA’s website related to these changes are listed below (including EPA Hyperlinks). We have until August 15, 2024, to provide our feedback on these changes.
- MFNC Resources
- MFNC Stakeholder Feedback Form (WORD, 156 KB) – Stakeholders are directed to use this form to submit comments on the MFNC proposals no later than August 15, 2024.
- Webinar Slides on the Key Proposals for Revision 05 (PDF, 1.28 MB) – Slides from the webinar that EPA held on July 17, 2024, to introduce the key proposals for Revision 05, explain the comment period process, and answer questions.
- Webinar Recording on the Key Proposals for Revision 05 – Recording of the webinar that EPA held on July 17, 2024.
- ASHRAE Path Fuel Neutral Approach Additional Feedback Documents:
- Instructions to Calculate Fuel Neutral Savings (PDF, 1.86 MB) – Instructions for using the files below to calculate savings with proposed fuel neutral approach.
- 90.1 Performance-based Compliance Form V4.1.xlsm (Excel, 4.85 MB) – Most recent DOE 90.1 Performance-based Compliance Form.
- 90.1 Performance-based Compliance Form Companion Tool MFNC_ZERH Version 1 Draft (Excel, 4.51 MB) – Draft Tool that uses compliance form data to calculate savings using the proposed fuel neutral approach.
- Building Efficiency Characteristics Form (WORD, 47 KB)
I remember in 2015 the State of California was trying to pass a submetering requirement which mandated that, for multifamily sites, submeters needed to be physically installed or a water connection would not be provided. Our builders and submetering providers spoke up and shared with the lawmakers that you cannot install submeters without a water connection in place so the bill as written was putting the cart before the horse. The bill was modified based on our feedback.
If we let this deadline of 8/15/24 pass, we consent to all of EPA’s changes. I appreciate the recognition from EPA that our industry is complex. I appreciate that we have a month to provide feedback, which EPA wants.
Fun fact, in many jurisdictions, like the City of Los Angeles California, an energy star score on a building exempts it from requirements for audits. The certification saves the property owner potentially tens of thousands of dollars. Our ability to obtain these certifications will become more and more valuable to owners and operators.
My friends in construction, please take a minute to review these changes to the new construction certification process proposed by EPA and provide your feedback. If you don’t, you are agreeing with them as they are written.
Silence is consent.
