Forum discussion

Policy guidance on changes to energy code regarding heat pumps

Hello everyone. I am seeking some guidance on crafting an arguement for why my firm should support a change to the Washington State Energy Code which would mandate electric heat pumps for commercial builidngs.  AIA WA is working on the state commercial energy code update under consideration this spring.  We have been invited to sign on to an industry letter to the State Building Code Council in support of the two heat pump proposals (one for space heating and one for hot water heating) that are part of that update.  This is part of a larger campaign to secure passage of the heat pump proposals by Shift Zero, a zero net carbon building alliance in which AIA members play a major role.  The SBCC will vote on the code in April.

The gist of the letter (and the change to the state building code) is this:  We, the undersigned architects, designers, and building industry professionals operating in Washington, write to urge your leadership in supporting a commercial energy code that will enable us to achieve the state’s goal of zero carbon buildings by 2031. In particular, we support the adoption of a state building energy code that requires the use of efficient electric heat pumps for space and water heating in new commercial and large multifamily buildings.  The full letter is here: https://docs.google.com/forms/d/e/1FAIpQLSd5YJQepPL4YLvxilqqDp1l-kJDwi8soXHvBxELl3lDwFCl9Q/viewform

There is some disagreement in my firm about whether or not to sign this letter.  I am advocating that we sign.  The "No" arguement goes something like this:

While I do believe we should not shy away from using our name in support of things that align with our mission and goals and shared values, I do not believe we should ever advocate a prescriptive systems design solution as a mandate from a jurisdictional authority.  The goals here is full electrification and elimination of fossil fuel burning for heating.  That’s great, but doing that by mandating a system takes the authority for finding the best solution out of our hands as designers, creates a law or a rule or a regulation that lives in perpetuity beyond the usefulness of the technology, and becomes a pork-filled boondoggle for specific industry (in this case, Mitsubishi).  I would rather see performance based incentives and punishments through regulatory agencies and jurisdictional authorities as the most successful means to combat climate change.

This is a regulatory wonk arguement that I don't feel qualified to answer.  My response has been that regulations work for all kinds of behaviour that we want to disincentivize, and the building code is our best tool for reducing carbon emissions from buildings.  I'm looking for some guidance from some of you out there who are true policy experts and who would like to help me by suggesting a rebuttal to the "No" position.  I hope to persuade our Board of Directors to sign the letter.

I will be grateful for any help from the group.

Thank You, 

Patrick

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Mon, 02/14/2022 - 16:35

My response to this part: "mandating a system takes the authority for finding the best solution out of our hands as designers...I would rather see performance based incentives" is that many designers/builders, especially on the smaller end of the project scale, don't necessarily have the resources to keep up with technological changes and understand what system(s) will hit those performance targets. You're hearing this argument from within your firm, which has someone in a sustainability leader position and a record of high-performing projects, and that's not exactly standard in the industry. Performance incentives are great, but are they intuitive? well publicized and clearly communicated? Or are they another series of hoops to jump through for an uncertain reward? Are they the most effective means of getting past the resistance (no pun intended) to heat pumps from designers and builders who are accustomed to business as usual and don't have an energy expert on staff keeping up with advances that make heat pumps a cost-effective option in a cold climate now? In other words the prescriptive standard takes this decision out of YOUR hands as designers and some would see that as a bad thing, taking away your ability to be flexible and innovative. But for smaller firms, design-build firms, mechanical contractors etc, having the decision taken out of their hands can be a good thing, a piece of simple and clear guidance rather than a complex policy/technology landscape they need dedicated time and expertise to navigate. This is something I heard multiple times in local policy discussions over the past year - simplify, give contractors and designers resources, tell us what to do and help us do it, don't make decarbonization something you need to be a sustainability expert to do. As for the argument that it's a gift to Mitsubishi, I am just thinking out loud here and am not an expert but...I think you could spin that the opposite way: there's a bit of a monopoly right now because the U.S. doesn't have a well-developed heat pump market right now. If heat pump systems are the default, demand grows and creates opportunities for other manufacturers to enter or grow within the local market. Worth considering that the U.S. heat pump market will only grow from here, and how that might play out in places with/without a prescriptive mandate. 

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