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7.A. - Page 57 of 285 2019 Energy Efficiency Ordinance Cost-effectiveness Study The Reach Codes Team selected packages and measures based on cost-effectiveness as well as decades of experience with residential architects, builders, and engineers along with general knowledge of the relative acceptance of many measures. 2.2.1 Federal Preemption The Department of Energy (DOE) sets minimum efficiency standards for equipment and appliances that are federally regulated under the National Appliance Energy Conservation Act (NAECA), including heating, cooling, and water heating equipment. Since state and local governments are prohibited from adopting policies that mandate higher minimum efficiencies than the federal standards require, the focus of this study is to identify and evaluate cost-effective packages that do not include high efficiency equipment. While this study is limited by federal preemption, in practice builders may use any package of compliant measures to achieve the performance goals, including high efficiency appliances. Often, these measures are the simplest and most affordable measures to increase energy performance. 2.2.2 Energy Design Rating The 2019 Title 24 code introduces California's Energy Design Rating (EDR) as the primary metric to demonstrate compliance with the energy code. EDR is still based on TDV but it uses a building that is compliant with the 2006 International Energy Conservation Code (IECC) as the reference building. The reference building has an EDR score of 100 while a zero -net energy (ZNE) home has an EDR score of zero (Energy Commission, 2018d). See Figure 1 for a graphical representation of this. While the Reference Building is used to determine the rating, the Proposed Design is still compared to the Standard Design based on the prescriptive baseline assumptions to determine compliance. The EDR is calculated by CBECC-Res and has two components: 1. An "Efficiency EDR" which represents the building's energy use without solar generation.4 2. A "Total EDR" that represents the final energy use of the building based on the combined impact of efficiency measures, PV generation and demand flexibility. For a building to comply, two criteria are required: (1) the proposed Efficiency EDR must be equal to or less than the Efficiency EDR of the Standard Design, and (2) the proposed Total EDR must be equal to or less than the Total EDR of the Standard Design. Single family prototypes used in this analysis that are minimally compliant with the 2019 Title 24 code achieve a Total EDR between 20 and 35 in most climates. This concept, consistent with California's "loading order" which prioritizes energy efficiency ahead of renewable generation, requires projects meet a minimum Efficiency EDR before PV is credited but allows for PV to be traded off with additional efficiency when meeting the Total EDR. A project may improve on building efficiency beyond the minimum required and subsequently reduce the PV generation capacity required to achieve the required Total EDR but may not increase the size of the PV system and trade this off with a reduction of efficiency measures. Figure 1 graphically summarizes how both Efficiency EDR and PV / demand flexibility EDR are used to calculate the Total EDR used in the 2019 code and in this analysis. 4 While there is no compliance credit for solar PV as there is under the 2016 Standards, the credit for installing electric storage battery systems that meet minimum qualifications can be applied to the Efficiency EDR. 4 © 2019-08-01 309