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Analysis of the ENERGY STAR
  Reference Home Concept as
Proposed for EPA’s 2011National
    Program Requirements

                          FSEC-RR-342-09



                            Research Report
                                June 14, 2009




                                   Author
                                 Philip Fairey



    Copyright © 2009 Florida Solar Energy Center/University of Central Florida
                                All rights reserved.
Analysis of the ENERGY STAR Reference Home Concept
                 as Proposed for EPA’s 2011 National Program Requirements 1

                                               Philip Fairey
                                       Florida Solar Energy Center
                                              June 14, 2009

Introduction
                       ®
Using EnergyGauge USA v.2.8.02, the Florida Solar Energy Center (FSEC) has conducted an
analysis of EPA’s proposed ENERGY STAR Reference Design Home specification. A single-
story, 2344 ft2, slab-on-grade, 3-bedroom, frame home is evaluated in each of the seven
contiguous U.S. climate zones. The ENERGY STAR Reference Design Home was evaluated
using three metrics: 1) EPS’s threshold qualifying HERS Index (including the Size Adjustment
Factor – 0.984 for this home), 2) the 2006 IECC Standard Reference Design and 3) the 2009
IECC Standard Reference Design. Evaluations using the IECC Standard Reference Design were
computed using source energy, where the source energy factors were 3.16 for electricity use and
1.1 for natural gas use. 2 For the IECC analyses, results are expressed as an e-Ratio, where the
total source energy use for heating, cooling and hot water for the ENERGY STAR Reference
Design Home is divided by the total source energy use for heating, cooling and hot water for the
IECC Standard Design Home, as follows:

                  e-Ratio = (e-Star RefDsn energy use) / (IECC StdDsn energy use)

The EnergyGauge simulations were conducted using TMY3 weather data for the following
standard climate zones and TMY weather sites:
    CZ1 – Miami, FL
    CZ2 – Daytona Beach, FL
    CZ3 – Dallas, TX
    CZ4 – St. Louis, MO
    CZ5 – Indianapolis, IN
    CZ6 – Burlington, VT
    CZ7 – Duluth, MN

The analysis is limited in scope. The following limitations should be considered when reviewing
the results.

    •   Only a single home size is represented. Larger homes or smaller homes with the same
        Size Adjustment Factor will necessarily produce slightly different results
    •   Only a single foundation type is represented. Crawl space foundations, basement
        foundations and mixed foundations will produce different results
    •   Only a limited number of weather sites have been considered. Other TMY3 weather sites
        will likely yield slightly different results.
1
  EPA, “Proposed New Guidelines for ENERGY STAR Qualified New Homes”
http://www.energystar.gov/index.cfm?c=bldrs_lenders_raters.nh_2011_comments
2
  In accordance with Section 405.3, 2009 International Energy Conservation Code (IECC)

                                                                                               1
Notwithstanding the above limitations, the analysis is instructive with regard to EPA’s proposed
specification for an ENERGY STAR Reference Design Home.

Results

Results are presented in chart format. Figure 1 shows the qualifying HERS Index for the
ENERGY STAR Reference Design Home in each of the seven climates for homes equipped with
electric heat pumps and with natural gas
furnaces. Figure 1 clearly shows that,
with respect to the HERS Index, the
ENERGY STAR Reference Design home
is quite sensitive to climate and even more
sensitive to the fuel type of the selected
heating system. If the home is located in
a cold climate, the electric heat pump
provides a significantly larger HERS
Index than the natural gas furnace. It is
also clear from the data that there is a
substantial difference in qualifying HERS
Index across climates, where the same
                                             Figure 1. Qualifying HERS Index for selected home in seven
heat pump equipped home requires a
                                             climate zones, showing qualifying HERS Index criteria for
HERS Index of 69 in Miami, FL, and 84        homes with electric heat pumps and natural gas furnaces.
in Duluth, MN.

To determine the degree to which the characteristics in Figure 1 are solely a function of the
RESNET method of evaluation, the ENERGY STAR Reference Design home was also evaluated
against the 2006 IECC Standard Design Home and the 2009 IECC Standard Design Home.
Results of the 2006 IECC evaluation are shown in Figure 2. This analysis is conducted using a
different comparison method than the
HERS method. For the HERS method,
normalized, modified loads are used to
determine the HERS Index. For Figure 2,
an energy use ratio (e-Ratio) is
determined by dividing the source energy
use for the ENERGY STAR Reference
Design Home by the source energy use
for the IECC Standard Reference Design.
Thus, an e-Ratio of 0.80 means that the
ENERGY STAR Reference Design Home
uses 80% as much source energy as the
2006 IECC Standard Reference Design
home (i.e. it saves 20% compared to that     Figure 2. Comparison of the ENERGY STAR Reference
                                             Design Home against the 2006 IECC in seven climates,
standard). The same trends exist in          showing the IECC 2006 e-Ratio for homes with electric heat
Figure 2, where the ENERGY STAR              pumps and gas furnaces.
Reference Design Home is compared
against the 2006 IECC, as exist in Figure 1,where it is compared against the HERS Index.

                                                                                                     2
If site energy use rather than source energy use is used to make the comparisons, there is a
slightly greater difference between heat pumps and gas furnaces in cold climates, with the
e-Ratios for the heat pump home remaining the same and the e-Ratios for the gas furnace homes
decreasing slightly.

The second code analysis uses the 2009 IECC Standard Reference Design 3 as the basis of
comparison. Figure 3 presents results from this analysis. With the exception a slight change for
climate zone 3 (Dallas, TX), the patterns
shown in Figure 3 are virtually identical
to those shown in Figure 2. The
additional item showing up in Figure 3 is
the fact that ENERGY STAR Reference
Design Homes with heat pumps
sometimes barely comply with the 2009
IECC in cold climates. This is likely due
to the fact that the ENERGY STAR
Reference Design Home specification
calls for an 18% window-floor area ratio
while the 2009 IECC specification limits
window-floor area ratio to 15%.
                                                   Figure 3. Comparison of the ENERGY STAR Reference
Nonetheless, the same patterns emerge in           Design Home against the 2009 IECC in seven climates,
the IECC 2009 analysis, with the                   showing the IECC 2009 e-Ratio for homes with electric heat
                                                   pumps and gas furnaces.
ENERGY STAR Reference Design
Home being significantly more stringent (with respect to the model code) in southern, warm
climates than it is in northern, cold climates. While this difference is exaggerated in electric heat
pump homes, it is also significant in homes with gas furnaces. For example, while the estimated
savings with respect to the 2009 IECC for the ENERGY STAR Reference Design Home
equipped with a gas furnace are 19% in
Miami, FL, they are only 8% in St. Louis.

To determine the degree of correlation
between the 2009 IECC e-Ratios and the
HERS Indices for the ENERGY STAR
Reference Design Home, the e-Ratio data
shown in Figure 3 were regressed against
the HERS Index data shown in Figure 1.
The result, presented in Figure 4, shows a
quite good correlation between these two
metrics, with a correlation coefficient
(R-square) of 0.9589. This indicates that
the HERS Index correlates well with the Figure 4. Correlation between 2009 IECC e-Ratio and the
minimum requirements of the 2009 IECC HERS Index for the ENERGY STAR Reference Design.


3
 To facilitate comparison, the thermostat set points for the 2009 IECC Standard Reference Design were maintained
at the same temperatures as the 2006 IECC Standard Reference Design and the HERS Reference Home.

                                                                                                                3
when source energy use is the metric for determining energy savings relative to the minimum
requirements of the 2009 IECC.

Since this correlation appears valid, additional analyses are conducted to examine the HERS
Index for the home size/bedroom pair sets provided in EPA’s Exhibit 3: Benchmark Home Size.
For each of the eight size/bedroom pair sets, an IECC 2009 Standard Reference Design Home is
constructed for each of the seven contiguous U.S. climates, yielding 56 distinct IECC 2009
Standard Reference Design homes. Since EPA’s proposed standard includes a requirement for
mechanical ventilation in accordance with ASHRAE Standard 62.2, the minimum standard
mechanical ventilation system was included in these IECC 2009 Standard Reference Design
homes. Each of the 56 homes is evaluated for its HERS Index using the EnergyGauge rating
software. Once the individual HERS Indices are determined, they are averaged across all climate
zones by home size, yielding an average HERS Index for homes of the specified size and number
of bedrooms.

It is the stated policy of EPA that their ENERGY STAR new homes program produces homes
that are at least 15% more efficient than required by codes. Thus, the resulting average HERS
Indices are multiplied by 0.85 to determine a minimum qualifying HERS Index for a program
that is 15% more efficient than the 2009 IECC across climates. The results from this analysis are
provided in Table 1.

                Table 1. HERS Index for IECC 2009 Standard Reference Design Homes of
                         Specified Size and Number of Bedrooms across U.S. Climate Zones
                      2
  Cond. floor area (ft ): 1000 1600 2200 2800 3400 4000 4600 5200                          Range
         No. bedrooms:       1        2      3      4       5      6       7       8     (max-min)
  Miami (CZ1)               90        89     88     88     87     87       87     87        3.0
  Daytona Bch (CZ2)         91        90     89     89     88     88       88     88        3.0
  Dallas (CZ3)              89        88     87     87     86     86       86     86        3.0
  St. Louis (CZ4)           91        90     89     88     88     88       88     87        4.0
  Indianapolis (CZ5)        92        91     91     90     90     90       89     89        3.0
  Burlington (CZ6)          93        93     93     93     92     92       92     92        1.0
  Duluth (CZ7)              93        93     93     92     92     92       92     92        1.0
                Average: 91.3 90.6 90.0 89.6 89.0 89.0 88.9 88.7                            2.6
        85% of Average: 77.6 77.0 76.5 76.1 75.7 75.7 75.5 75.4                             2.2

The range of resulting HERS Indices are given in Table 1 for each climate. These ranges show
that the maximum range occurs in St. Louis (CZ4) at 4 HERS points. The minimum range
occurs in both Burlington (CZ6) and Duluth (CZ7) at only 1 HERS point. It is important to also
note that EnergyGauge does not produce decimal HERS Indices, so the HERS Indices presented
in Table 1 are rounded values.

A regression analysis is performed to determine the “goodness of fit” for the resulting “85% of
Average” HERS Indices. The values for the 3400 ft2 and the 4600 ft2 homes were omitted from
the regression analysis. They were omitted due to the fact that the values for the 3400 ft2 home
are identical to the values for the 4000 ft2 home. One sees from Table 1 that this is due to the
fact that the HERS Indices are not determined to their decimal values, leading to the values for

                                                                                                     4
the 3400 ft2 and 4000ft2 homes being identical in all climates. It is evident from the data that the
differences in HERS Index across home sizes is non linear, with larger differences occurring for
the smaller home sizes. As a result of these observations, every other home following the 2800
ft2 home (3400 ft2 and 4600 ft2) was
omitted from the analysis.

The results are shown graphically in
Figure 5. The regression equation is non-
linear, as expected, and is very well
correlated with the HERS Index results,
showing a correlation coefficient (R-
square) of 0.999. Due to the fact that the
HERS Index values are not calculated to
their decimal values, the curve fit is
actually more accurate than the raw data.
This fact can be explicitly seen in the data
for the 3400 ft2 home which has identical       Figure 5. 85% of Average IECC 2009 Standard Reference
values as the 4000 ft2 home. This point,        Design HERS Index as a function of home size, showing
due to rounding of the HERS Indices,            regression results. (Note that results from the 3400 ft2 and
                                                4600 ft2 homes were omitted from the regression analysis.)
represents a distinct outlier with respect to
the remainder of the home sizes.

Recommendations

While it is clear that the current HERS Index is not independent of home size, the relationship is
not pronounced for the ENERGY STAR Reference Design home. This is probably due to the
fact that the number of bedrooms (which functions as the surrogate for the number of occupants
and impacts hot water use, internal gains, etc.) is incremented for each 600 ft2 increment of
conditioned floor area for these homes. It is also important to note at this point that this size
dependency is a matter of physics and that it also exists in performance-based code compliance
methods as well. The proposed ENERGY STAR Reference Design Home concept was
developed in part to resolve this challenge.

However, as noted above, the proposed produces energy savings that cannot be directly related to
the national model energy codes, yielding differing efficiency improvements with respect to
codes in hot, mixed and cold climates. As shown if Figure 3, the EPA ENERGY STAR
Reference Design Home proposal would allow homes that are only 1% - 5% more efficient than
the minimum requirements of the 2009 IECC. This is counter to EPA’s stated policy goal of
achieving at least 15% savings with respect to prevailing minimum standards. It is
recommended that EPA seriously reconsider their treatment of heat pumps in this regard. Figure
3 also illustrates that even gas furnaces are unlikely to satisfy their policy goal in climate zone 4,
where only 8% savings with respect to IECC 2009 are shown.

EPA has stated that one of their concerns and one of the reasons that they propose the ENERGY
STAR Reference Design Home concept stems from the fact that the HERS Index advantages
large homes and disadvantages small homes. The use of an ENERGY STAR Reference Design

                                                                                                               5
Home would resolve this size challenge. While this may be true in the narrow sense, as has been
shown here, use of the proposed ENERGY STAR Reference Design Home would also generate
other issues with potentially more profound impacts than home size.

However, the analysis presented above offers a potential solution to these challenges. It is
recommended that EPA add a third row to their Exhibit 3: Benchmark Home Size table. This
row should contain the Base HERS Index that is required to achieve a performance level that
exceeds national model codes by 15%. Table 2, below, is provided as an example:

           Table 2. Example Expansion of EPA Exhibit 3: Benchmark Home Sizes
    No. of Bedrooms        1      2       3      4        5      6     7      8
    Benchmark CFA       1,000 1,600 2,200 2,800 3,400 4,000 4,600 5,200
    Base HERS Index       78     77      77     76       76     76    76     75

It is important to point out that Table 2 is only presented as an example and that the values
shown for the Base HERS Index should be considered only “placeholders.” While these values
stem from the preceding analysis, this analysis is limited to only a single home type. If EPA
chooses to adopt this approach, it is recommended that they conduct a national analysis to
develop a final set of Base HERS Indices. It is recommended that such analysis consist, at a
minimum, of the following steps:

   1. Determine HERS Index for IECC 2009 Standard Reference Design for all home sizes, in
      all climates for all reasonable foundation types using electric space air conditioning, gas
      furnace space heating and gas hot water heating in all climates.
   2. Determine the average HERS Index for each home size across all climates and all
      building foundation types (this average could just as well be a weighted average based on
      expected or historic home starts).
   3. Multiply the resulting average HERS Indices by 85% to establish the Base HERS Index
      for each base home size (Benchmark CFA).
   4. Use actual home size (CFA) and EPA’s proposed Size Adjustment Factor (SAF) to
      establish the “Qualifying HERS Index” for proposed ENERGY STAR homes.
   5. Adjust BOP requirements to be in line with the above.

The above procedures will resolve some of the largest challenges with respect to advancement
the ENERGY STAR new homes program. It will document and explicitly remove the home size
factor that currently advantages larger homes and disadvantages smaller homes. It will achieve
EPA’s policy objective of providing ENERGY STAR new homes that are at least 15% more
efficient than prevailing national model codes. It will also provide clear guidance to builders and
consumers regarding the HERS Indices that are expected from ENERGY STAR labeled homes.
And when coupled with EPA’s proposed Size Adjustment Factor, it is likely to seriously impact
home size selection. For example, if a builder or homeowner chooses to build a 5,000 ft2,
3-bedroom home, they will quickly and easily be able to determine from EPA’s qualification
guidelines that the required qualifying HERS Index for this home is 76*(2200/5000)0.25 = 62.
This level of explicitness likely will result in additional success for EPA’s home size initiative.




                                                                                                 6

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Analysis of the ENERGY STAR Reference Home Concept as Proposed for EPA’s 2011 National Program Requirements

  • 1. Analysis of the ENERGY STAR Reference Home Concept as Proposed for EPA’s 2011National Program Requirements FSEC-RR-342-09 Research Report June 14, 2009 Author Philip Fairey Copyright © 2009 Florida Solar Energy Center/University of Central Florida All rights reserved.
  • 2. Analysis of the ENERGY STAR Reference Home Concept as Proposed for EPA’s 2011 National Program Requirements 1 Philip Fairey Florida Solar Energy Center June 14, 2009 Introduction ® Using EnergyGauge USA v.2.8.02, the Florida Solar Energy Center (FSEC) has conducted an analysis of EPA’s proposed ENERGY STAR Reference Design Home specification. A single- story, 2344 ft2, slab-on-grade, 3-bedroom, frame home is evaluated in each of the seven contiguous U.S. climate zones. The ENERGY STAR Reference Design Home was evaluated using three metrics: 1) EPS’s threshold qualifying HERS Index (including the Size Adjustment Factor – 0.984 for this home), 2) the 2006 IECC Standard Reference Design and 3) the 2009 IECC Standard Reference Design. Evaluations using the IECC Standard Reference Design were computed using source energy, where the source energy factors were 3.16 for electricity use and 1.1 for natural gas use. 2 For the IECC analyses, results are expressed as an e-Ratio, where the total source energy use for heating, cooling and hot water for the ENERGY STAR Reference Design Home is divided by the total source energy use for heating, cooling and hot water for the IECC Standard Design Home, as follows: e-Ratio = (e-Star RefDsn energy use) / (IECC StdDsn energy use) The EnergyGauge simulations were conducted using TMY3 weather data for the following standard climate zones and TMY weather sites: CZ1 – Miami, FL CZ2 – Daytona Beach, FL CZ3 – Dallas, TX CZ4 – St. Louis, MO CZ5 – Indianapolis, IN CZ6 – Burlington, VT CZ7 – Duluth, MN The analysis is limited in scope. The following limitations should be considered when reviewing the results. • Only a single home size is represented. Larger homes or smaller homes with the same Size Adjustment Factor will necessarily produce slightly different results • Only a single foundation type is represented. Crawl space foundations, basement foundations and mixed foundations will produce different results • Only a limited number of weather sites have been considered. Other TMY3 weather sites will likely yield slightly different results. 1 EPA, “Proposed New Guidelines for ENERGY STAR Qualified New Homes” http://www.energystar.gov/index.cfm?c=bldrs_lenders_raters.nh_2011_comments 2 In accordance with Section 405.3, 2009 International Energy Conservation Code (IECC) 1
  • 3. Notwithstanding the above limitations, the analysis is instructive with regard to EPA’s proposed specification for an ENERGY STAR Reference Design Home. Results Results are presented in chart format. Figure 1 shows the qualifying HERS Index for the ENERGY STAR Reference Design Home in each of the seven climates for homes equipped with electric heat pumps and with natural gas furnaces. Figure 1 clearly shows that, with respect to the HERS Index, the ENERGY STAR Reference Design home is quite sensitive to climate and even more sensitive to the fuel type of the selected heating system. If the home is located in a cold climate, the electric heat pump provides a significantly larger HERS Index than the natural gas furnace. It is also clear from the data that there is a substantial difference in qualifying HERS Index across climates, where the same Figure 1. Qualifying HERS Index for selected home in seven heat pump equipped home requires a climate zones, showing qualifying HERS Index criteria for HERS Index of 69 in Miami, FL, and 84 homes with electric heat pumps and natural gas furnaces. in Duluth, MN. To determine the degree to which the characteristics in Figure 1 are solely a function of the RESNET method of evaluation, the ENERGY STAR Reference Design home was also evaluated against the 2006 IECC Standard Design Home and the 2009 IECC Standard Design Home. Results of the 2006 IECC evaluation are shown in Figure 2. This analysis is conducted using a different comparison method than the HERS method. For the HERS method, normalized, modified loads are used to determine the HERS Index. For Figure 2, an energy use ratio (e-Ratio) is determined by dividing the source energy use for the ENERGY STAR Reference Design Home by the source energy use for the IECC Standard Reference Design. Thus, an e-Ratio of 0.80 means that the ENERGY STAR Reference Design Home uses 80% as much source energy as the 2006 IECC Standard Reference Design home (i.e. it saves 20% compared to that Figure 2. Comparison of the ENERGY STAR Reference Design Home against the 2006 IECC in seven climates, standard). The same trends exist in showing the IECC 2006 e-Ratio for homes with electric heat Figure 2, where the ENERGY STAR pumps and gas furnaces. Reference Design Home is compared against the 2006 IECC, as exist in Figure 1,where it is compared against the HERS Index. 2
  • 4. If site energy use rather than source energy use is used to make the comparisons, there is a slightly greater difference between heat pumps and gas furnaces in cold climates, with the e-Ratios for the heat pump home remaining the same and the e-Ratios for the gas furnace homes decreasing slightly. The second code analysis uses the 2009 IECC Standard Reference Design 3 as the basis of comparison. Figure 3 presents results from this analysis. With the exception a slight change for climate zone 3 (Dallas, TX), the patterns shown in Figure 3 are virtually identical to those shown in Figure 2. The additional item showing up in Figure 3 is the fact that ENERGY STAR Reference Design Homes with heat pumps sometimes barely comply with the 2009 IECC in cold climates. This is likely due to the fact that the ENERGY STAR Reference Design Home specification calls for an 18% window-floor area ratio while the 2009 IECC specification limits window-floor area ratio to 15%. Figure 3. Comparison of the ENERGY STAR Reference Nonetheless, the same patterns emerge in Design Home against the 2009 IECC in seven climates, the IECC 2009 analysis, with the showing the IECC 2009 e-Ratio for homes with electric heat pumps and gas furnaces. ENERGY STAR Reference Design Home being significantly more stringent (with respect to the model code) in southern, warm climates than it is in northern, cold climates. While this difference is exaggerated in electric heat pump homes, it is also significant in homes with gas furnaces. For example, while the estimated savings with respect to the 2009 IECC for the ENERGY STAR Reference Design Home equipped with a gas furnace are 19% in Miami, FL, they are only 8% in St. Louis. To determine the degree of correlation between the 2009 IECC e-Ratios and the HERS Indices for the ENERGY STAR Reference Design Home, the e-Ratio data shown in Figure 3 were regressed against the HERS Index data shown in Figure 1. The result, presented in Figure 4, shows a quite good correlation between these two metrics, with a correlation coefficient (R-square) of 0.9589. This indicates that the HERS Index correlates well with the Figure 4. Correlation between 2009 IECC e-Ratio and the minimum requirements of the 2009 IECC HERS Index for the ENERGY STAR Reference Design. 3 To facilitate comparison, the thermostat set points for the 2009 IECC Standard Reference Design were maintained at the same temperatures as the 2006 IECC Standard Reference Design and the HERS Reference Home. 3
  • 5. when source energy use is the metric for determining energy savings relative to the minimum requirements of the 2009 IECC. Since this correlation appears valid, additional analyses are conducted to examine the HERS Index for the home size/bedroom pair sets provided in EPA’s Exhibit 3: Benchmark Home Size. For each of the eight size/bedroom pair sets, an IECC 2009 Standard Reference Design Home is constructed for each of the seven contiguous U.S. climates, yielding 56 distinct IECC 2009 Standard Reference Design homes. Since EPA’s proposed standard includes a requirement for mechanical ventilation in accordance with ASHRAE Standard 62.2, the minimum standard mechanical ventilation system was included in these IECC 2009 Standard Reference Design homes. Each of the 56 homes is evaluated for its HERS Index using the EnergyGauge rating software. Once the individual HERS Indices are determined, they are averaged across all climate zones by home size, yielding an average HERS Index for homes of the specified size and number of bedrooms. It is the stated policy of EPA that their ENERGY STAR new homes program produces homes that are at least 15% more efficient than required by codes. Thus, the resulting average HERS Indices are multiplied by 0.85 to determine a minimum qualifying HERS Index for a program that is 15% more efficient than the 2009 IECC across climates. The results from this analysis are provided in Table 1. Table 1. HERS Index for IECC 2009 Standard Reference Design Homes of Specified Size and Number of Bedrooms across U.S. Climate Zones 2 Cond. floor area (ft ): 1000 1600 2200 2800 3400 4000 4600 5200 Range No. bedrooms: 1 2 3 4 5 6 7 8 (max-min) Miami (CZ1) 90 89 88 88 87 87 87 87 3.0 Daytona Bch (CZ2) 91 90 89 89 88 88 88 88 3.0 Dallas (CZ3) 89 88 87 87 86 86 86 86 3.0 St. Louis (CZ4) 91 90 89 88 88 88 88 87 4.0 Indianapolis (CZ5) 92 91 91 90 90 90 89 89 3.0 Burlington (CZ6) 93 93 93 93 92 92 92 92 1.0 Duluth (CZ7) 93 93 93 92 92 92 92 92 1.0 Average: 91.3 90.6 90.0 89.6 89.0 89.0 88.9 88.7 2.6 85% of Average: 77.6 77.0 76.5 76.1 75.7 75.7 75.5 75.4 2.2 The range of resulting HERS Indices are given in Table 1 for each climate. These ranges show that the maximum range occurs in St. Louis (CZ4) at 4 HERS points. The minimum range occurs in both Burlington (CZ6) and Duluth (CZ7) at only 1 HERS point. It is important to also note that EnergyGauge does not produce decimal HERS Indices, so the HERS Indices presented in Table 1 are rounded values. A regression analysis is performed to determine the “goodness of fit” for the resulting “85% of Average” HERS Indices. The values for the 3400 ft2 and the 4600 ft2 homes were omitted from the regression analysis. They were omitted due to the fact that the values for the 3400 ft2 home are identical to the values for the 4000 ft2 home. One sees from Table 1 that this is due to the fact that the HERS Indices are not determined to their decimal values, leading to the values for 4
  • 6. the 3400 ft2 and 4000ft2 homes being identical in all climates. It is evident from the data that the differences in HERS Index across home sizes is non linear, with larger differences occurring for the smaller home sizes. As a result of these observations, every other home following the 2800 ft2 home (3400 ft2 and 4600 ft2) was omitted from the analysis. The results are shown graphically in Figure 5. The regression equation is non- linear, as expected, and is very well correlated with the HERS Index results, showing a correlation coefficient (R- square) of 0.999. Due to the fact that the HERS Index values are not calculated to their decimal values, the curve fit is actually more accurate than the raw data. This fact can be explicitly seen in the data for the 3400 ft2 home which has identical Figure 5. 85% of Average IECC 2009 Standard Reference values as the 4000 ft2 home. This point, Design HERS Index as a function of home size, showing due to rounding of the HERS Indices, regression results. (Note that results from the 3400 ft2 and 4600 ft2 homes were omitted from the regression analysis.) represents a distinct outlier with respect to the remainder of the home sizes. Recommendations While it is clear that the current HERS Index is not independent of home size, the relationship is not pronounced for the ENERGY STAR Reference Design home. This is probably due to the fact that the number of bedrooms (which functions as the surrogate for the number of occupants and impacts hot water use, internal gains, etc.) is incremented for each 600 ft2 increment of conditioned floor area for these homes. It is also important to note at this point that this size dependency is a matter of physics and that it also exists in performance-based code compliance methods as well. The proposed ENERGY STAR Reference Design Home concept was developed in part to resolve this challenge. However, as noted above, the proposed produces energy savings that cannot be directly related to the national model energy codes, yielding differing efficiency improvements with respect to codes in hot, mixed and cold climates. As shown if Figure 3, the EPA ENERGY STAR Reference Design Home proposal would allow homes that are only 1% - 5% more efficient than the minimum requirements of the 2009 IECC. This is counter to EPA’s stated policy goal of achieving at least 15% savings with respect to prevailing minimum standards. It is recommended that EPA seriously reconsider their treatment of heat pumps in this regard. Figure 3 also illustrates that even gas furnaces are unlikely to satisfy their policy goal in climate zone 4, where only 8% savings with respect to IECC 2009 are shown. EPA has stated that one of their concerns and one of the reasons that they propose the ENERGY STAR Reference Design Home concept stems from the fact that the HERS Index advantages large homes and disadvantages small homes. The use of an ENERGY STAR Reference Design 5
  • 7. Home would resolve this size challenge. While this may be true in the narrow sense, as has been shown here, use of the proposed ENERGY STAR Reference Design Home would also generate other issues with potentially more profound impacts than home size. However, the analysis presented above offers a potential solution to these challenges. It is recommended that EPA add a third row to their Exhibit 3: Benchmark Home Size table. This row should contain the Base HERS Index that is required to achieve a performance level that exceeds national model codes by 15%. Table 2, below, is provided as an example: Table 2. Example Expansion of EPA Exhibit 3: Benchmark Home Sizes No. of Bedrooms 1 2 3 4 5 6 7 8 Benchmark CFA 1,000 1,600 2,200 2,800 3,400 4,000 4,600 5,200 Base HERS Index 78 77 77 76 76 76 76 75 It is important to point out that Table 2 is only presented as an example and that the values shown for the Base HERS Index should be considered only “placeholders.” While these values stem from the preceding analysis, this analysis is limited to only a single home type. If EPA chooses to adopt this approach, it is recommended that they conduct a national analysis to develop a final set of Base HERS Indices. It is recommended that such analysis consist, at a minimum, of the following steps: 1. Determine HERS Index for IECC 2009 Standard Reference Design for all home sizes, in all climates for all reasonable foundation types using electric space air conditioning, gas furnace space heating and gas hot water heating in all climates. 2. Determine the average HERS Index for each home size across all climates and all building foundation types (this average could just as well be a weighted average based on expected or historic home starts). 3. Multiply the resulting average HERS Indices by 85% to establish the Base HERS Index for each base home size (Benchmark CFA). 4. Use actual home size (CFA) and EPA’s proposed Size Adjustment Factor (SAF) to establish the “Qualifying HERS Index” for proposed ENERGY STAR homes. 5. Adjust BOP requirements to be in line with the above. The above procedures will resolve some of the largest challenges with respect to advancement the ENERGY STAR new homes program. It will document and explicitly remove the home size factor that currently advantages larger homes and disadvantages smaller homes. It will achieve EPA’s policy objective of providing ENERGY STAR new homes that are at least 15% more efficient than prevailing national model codes. It will also provide clear guidance to builders and consumers regarding the HERS Indices that are expected from ENERGY STAR labeled homes. And when coupled with EPA’s proposed Size Adjustment Factor, it is likely to seriously impact home size selection. For example, if a builder or homeowner chooses to build a 5,000 ft2, 3-bedroom home, they will quickly and easily be able to determine from EPA’s qualification guidelines that the required qualifying HERS Index for this home is 76*(2200/5000)0.25 = 62. This level of explicitness likely will result in additional success for EPA’s home size initiative. 6