Community Discussions
Citations and Appendix
6. Codeword: Decarbonize

6. Codeword: Decarbonize

Discuss building codes and state regulations, including comparison between CA, WA, and OR.


6. Codeword: Decarbonize

Workshop Date: 05/04/2021 - 11:00 AM PT


Discuss building codes and state regulations, including comparison between CA, WA, and OR.



Opening Statements Codes and organizations representatives:

  • Dave Mason - OSHPD
  • Bill Gow - OSHPD
  • Kara Brooks - ASHE
  • Jeremy Fauber - ASHRAE 170
  • Michael Sheerin - ASHRAE 170
  • Tim Peglow - ASHRAE 90.1
  • Bing Liu - ASHRAE Building Decarbonization Task Force
  • David Eldridge - ASHRAE TC9.6 (170)
  • Brittany Carl Moser - ASHRAE 189.3

Breakout rooms:

  • California Codes including:
    • OSHPD (Title 24, Part 4: California Mechanical Code)
    • CEC (Title 24, Part 6: California Energy Code and Part 11: California Green Building Standards Code)
  • ASHRAE 170 - Ventilation of Health Care Facilities
  • ASHRAE 90.1 - Energy Standard for Buildings Except Low-Rise Residential Buildings
  • FGI - Guidelines for Design and Construction of Hospitals

Regroup into the main room to share summary of breakout sessions

Continued discussion on Decarb Healthcare Community

Upcoming Workshops




  • Review current codes that are restricting identified decarbonizing technologies
  • Compare with other states' codes and highlight what is working outside CA.
  • Discuss what changes to the code could improve decarbonizing efforts
  • Discuss what changes to the permit process could improve decarbonizing efforts


Opening Remarks: “What role do codes play in decarbonization?”

(Mason) Technologies that are proposed aren’t hindered by mech or plumbing codes but high ventilation rates that are required cause a lot of energy to be spent on reheat.

(Gow) Need the federal govt and CMS to help with healthcare energy codes and develop new tech to replace diesel generators.

(Fauber) Wants to see codes be more open to new innovations and code group looking into new research that may allow different approaches.

(Sheerin) Reheat and ventilation requirements is an easy target to address. 170 currently struggles with what are appropriate ventilation levels for different spaces. Pandemic has made that a tougher issue as well. Potential in natural ventilation and other opportunities to reduce energy/carbon.

(Peglow) Where codes are in the cycle (current hearing process for ICC is for 2024) long lead times take a while for changes to take effect.

(Brooks) Hospitals are bound to old codes.

(Liu) Current codes have more impact on new construction than existing but existing buildings are source of carbon emissions. Need to develop codes to address existing buildings and how they can improve. Can be innovative, WA state codes are starting to regulate HVAC system efficiency. Build in the demand of the market.

(Eldridge) Look into prescriptive options and outcomes-based paths to leave design teams with flexibility on how they can address the measures.

(Moser) Standard 189.3 Sustainable design in Healthcare. Passive design in buildings standard 227 and how that standard aligns with 189.1 and 90.1.

Main Discussion

Do we have the codes that we need today for decarbonization?

(Brooks) We are getting closer, but we are bound by older codes. The CMS codes need to be changed first.

(Peglow) We have limitations on thought and ventilation standards, are there heat recovery options in healthcare that we aren't considering. Enthalpy in 90.1 are we as efficient in that or do we need to pursue other ideas.

(Moser) Organization of codes, coordination, and working together better between different standards committees is very important. Need to get resiliency into different sections of codes. Including factoring in renewable energy generation, storage, and grid harmonization.

What is the role of FGI? The ecosystem of codes

(FGI) the baseline of compliance could reference work of others in the appendix, doesn’t see decarbonization as the role of FGI.

(Peglow) If states or fed don’t adopt new codes, it will be useless.

(Vernon) NAM grand challenge with Don Berwick, had an 'aha' moment, created healthcare quality 6 dimensions, focus on environmental impact on future patients, bring embodied carbon into the conversation. Redefine 6 dimensions into 7 and add carbon.

(Liu) Bring embodied carbon into the codes, learn from WA and NYC.

(Mason) Approach any proposal to reduce ventilation rates in the code by building a strong deductive argument. Right now, we have three things to hang our hats on with the existing ventilation requirements: Florence Nightengale, Wells Riley, and very little research.

(Jackson) Decisions we make are based on failures in the past. New institute in NIH to deal with climate and health. $100M from Biden into the climate and health. Need a new institute with a powerful director. Need more research to identify outcomes.

(Eldridge) Outcomes-based codes.

(Crabb) connect what we do in our buildings with outcomes, but research will take time. Sympathetic to 170, standards go back to the 1950s. Basing vent rates on ACH. Not directly responsive to pollutants in the groups. 62.1 looks at ventilation from sources.

(Sheerin) Build other techs into long-term strategy, or into the code more sternly.

Did your code breakout session reference other codes?

(Peglow) in 90.1 we talked about 170 issue. Drove down consumption. If current standards existed as they do today.

(Mason) A reduction of ventilation rates in the code really should include the involvement of CMS. They hold influence over hospitals with funding.

(Vernon) Group with OSHPD and CEC. The CA Energy Code and CA Building Code somewhat conflicting. Need for balance since one is pushing for energy and the other is pushing for safety (restricting).

(Guttman) Low hanging fruit on existing buildings is identifying the problem. City of SF has to submit energy consumption baseline data each year. Requiring buildings to submit carbon data annually will begin to highlight how we start moving towards answers.

(Betz) Give facilities an evidence-based air change target and prove this number is safe, then the equation changes and it could be self-funded.

What about performance-based code?

(Liu) City of Boulder (outcome-based codes), current energy code structure in 90.1 and T24 has similar. Simulation-based. Constraints but its not outcome-based. NYC and WA states, outcome-based standards, mandatory to comply. Challenge is how to bridge gap to meet the desired targets. Policy and measurement requirement. Economic and policy challenge to solve at larger scale.

(Sheerin) Work with ASHE and performance benchmarking and share with 170. Maybe an incentive. Maybe CMS gives reimbursement rates.

(Brooks) Looked at some standards and look at the data for facilities and they don’t match. Performance targets are not being met. Maybe too stringent.

(Peglow) If you want carbon reductions, we need infrastructure funding and CMS support to get to the carbon targets for existing or new construction. We don’t have enough information today to say if we made changes to the code, what impact that would have on future carbon emissions.

Comments and Questions from the Chat

From Steven Guttmann: What is the role of FGI in this discussion? Are other Standard setting bodies really where responsibility should lie? And if these other bodies incorporate decarb strategies, how do we make sure that FGI adopts them?

From Fred Betz: What if any plan is in place to address air change rates in 170 to justify the expense and emissions associated with them?

From Walt Vernon: We invited FGI to participate, but they were unable. They did incorporate a requirement to comply with 90.1-2016 as a minimum this time (the 2022 edition).

From Jim Crabb: Kara's point about CMS is a good one. They have always lagged behind every other jurisdiction in adopting new versions of codes. Commonplace is the need to comply with both local/state codes and the older versions still enforced by CMS. So, the question is - how do we move the federal bureaucracy to be mode adept? Do we want them to just get out of the way, or should CMS start requiring carbon performance - maybe via an existing code. This may be a good chance for Dick Jackson to join in (hint hint).

From Walt Vernon: The ASHRAE Infectious Aerosols Position Document Committee is starting to consider looking at ventilation as a medical device, using Evidence Based Medicine thinking to inform requirements. That is, how much evidence do we have, how much benefit does something provide, and what are the costs, in money and carbon. We will see if that survives, but it won’t be fast enough.

From Fred Betz: Nice work Walt! Will that supersede state energy code requirements? How is that enforced?

From Walt Vernon: The requirement is to defer to local requirements, and only implement the 90.1 if there is no other code in force.

From John Pappas: Does anyone think we will ever get an agreement on the cost of carbon?

From Steven Guttmann: What about providing a target outdoor air "breakeven temperature" (heat loss thru the envelope is balanced by heat gain inside the building) by climate zone to get good envelope designs for all hospitals?

From Jim Crabb: What would you do with the breakeven temp, Steve?

From David Eldridge: The word of the day in our FGI breakout group was "outcomes" in that we need to quantify what happens if things are changed from where we've already drawn the line in the sand for instance ventilation rates. There was an observation that between different code versions that affected total ACH there weren't observed changes, or major changes, in patient outcomes. Then also we need an outcome-based path for energy performance as the codes squeeze energy out of prescriptive requirements we eventually will need to allow some flexibility for design teams to achieve a low-energy/low-carbon building given their local constraints.

From Walt Vernon: I am working with Don Berwick on the National Academy of Medicine work. He is saying that he wants to redefine healthcare quality to expand from six dimensions (equity, safety, etc) to seven - and include embodied carbon. So, if two interventions yield similar clinical outcomes, embodied carbon would tip the scale. I think this is an ethic that we should all adopt.

From Gail Lee: Agreed! We have to tie carbon back to our mission of improving health of our communities.

From John Griffiths: Underserved communities are disproportionally impacted by climate change and poor air quality. Recognizing this how can adopting of more sustainable solutions and code be accelerated to benefit these communities.

From Abdel Darwich: One other challenge with dealing with healthcare facilities energy or decarbonization codes is to clearly define "healthcare facilities" ? Like in CA, the energy code seems to define 'Healthcare' differently than other codes. Is inpatient only? outpatient? I-Occupancy? Licensed under H&SE?

From Fred Betz: ASHRAE 62.1-2019 has added a healthcare ventilation section. Read the footnotes so you're applying it to the right building type. I recently did this for a project and it's about a 50% energy savings.

From Walt Vernon: The ASHRAE Infections Aerosols Position Document has been calling since 200i9, for more research on the ventilation questions.

From David Eldridge: This was an interesting project I worked on this year and we did include a lot of information about containment approaches.

From David Eldridge: That's specifically not for hospitals though, it is for alternate care sites and use the required codes and standards for work within the healthcare facilities.

From Fred Betz: Agree David, but there were questions above related to outpatient and MOB facilities. Some of those should use 170, some should not.

From Kreg Eacret: The LA Community College District Board of Trustees adopted 100% Renewable Carbon Free Electricity Consumption by 2030//100% Carbon Free Energy Consumption for all other energy uses by 2040. The approach: Prepare Energy & Sustainability Plans//Establish energy baseline per campus//New Buildings must support these goals, new "energy projects" will be initiated to pursue the District objectives. Have HC systems (Kaiser, Dignity, Sutter, etc.) launched similar programs?

From David Eldridge: Yes, I have seen that in Healthcare.

From Austin Barolin: For reference, WA state Clean Buildings Bill has set EUI targets for all commercial buildings over 50k sf with a $75M incentive fund for early adopters and a penalty if compliance is not met by deadline (5-7 years). And NYC has set GHG emission limits based on building areas.

From Bing Liu: Standard 100 target (EUI) was developed based on CECS but it is not fine enough to reflect the local or regional building stock or benchmarking data. That is why in WA state it took us one year through rulemaking to customize the EUI target for commercial buildings in WA.

From Richard Jackson: There are so many excellent comments, many on the chat. I greatly appreciate the hotlinks that folks are sharing. I wonder if we could get a summary list?

From Steven Guttmann: A carbon tax would make it all simple. Studies suggest a carbon tax of $35 per MT would incent enough investment to meet our Paris Climate Accord commitments!


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