A key barrier to code adoption is not having a trained workforce both on the inspection and building sides.

Residential codes are getting close to the end of traditional energy efficiency measures.

Commercial building codes continue to grow more complex, necessitating a need to look at whole building and system performance metrics.

Coordinating across internal business units is an ongoing challenge.

C&S programs drive equity in appliance and equipment standards: once they take effect, they affect every unit sold to every customer regardless of income status or demographic.

C&S programs offer economies of scale in appliance or equipment standards.

To address the issue of increasing baseline, the Northwest counts savings attributable to C&S and reports them to all of the utilities. Most claim them as a part of their regulatory reporting.

C&S work requires specialized knowledge and skills, as it operates in politically charged arenas.

It is important to maintain a long-run view in C&S work – “if not this cycle, then the next.”

Even though their programs are in the early stages, they have seen an increase in the stability of savings from C&S once they are put in place.

New construction becomes less and less cost effective as it nears Net Zero, and code compliance training has provided a cost-effectiveness boost.

Savings dropped off significantly when only incentive portion of New Construction was allowed.

Leverage what already exists but act proactively where data is lacking. They pulled from west coast frameworks and focused on areas like existing buildings that are difficult to quantify.

Engage in C&S policy discussions as soon as possible.

To address the issue of increasing baselines, they are looking at tying compensation for supporting C&S advancement to the foregone earning opportunity that the utilities would have otherwise had.

Helping utilities show attribution for state standards.

Providing data on in-state sales and market share of products.

Allowing utilities to gain attribution for the work they do in standards development.

Ensuring that appliance standards are in state energy and/or climate plans. Some state statues give the authority to the Energy Office or Department of Commerce to set regulation. ASAP’s bill model provides proposed language to enable this authority.

Washington would benefit from a Market Transformation effort, like MEEA’s work in the Midwest.

The SEO relies heavily on NEEA for technical analysis and support, including cost effectiveness. NEEA is also the lead funder of training programs for residential and commercial energy codes.

The SEO has made sure that utilities are able to take credit for their mandatory efficiency programs in the context of these standards. Specifically, in relationship to the Energy Independence Act (which includes the state renewable energy and energy efficiency requirements), utilities continue to take credit for helping to implement these laws.

To be effective, legislation needs to be written in a way that is: enforceable, allows for continuous improvement, and does not go into too much detail.

Additional assessment work needs to be done in the areas of: The cost of increased performance levels; The technologies that are needed; and The sectors that are ready and need training. Legislation and state departments that support these codes.

If Minnesota elects to move beyond adopting national codes to creating them, additional resources, staffing and research would be needed. It is not typical for a state to have robust funding to develop code research. It would be more efficient and effective to share efforts across multiple states. There is significant research to be done on incremental cost and improving the supply chain.

Support municipal adoption because stretch code does not matter if no one adopts it. Their Green Communities program helps local efforts. Funding and technical assistance are essential. It is a multi-year process for many communities, and therefore a long-term commitment.

Support building code compliance by: Offering training for code officials and industry stakeholders and keeping it as simple as possible and certifying performance.

The residential sector offers the greatest opportunity, particularly in multifamily, where they get the greatest public engagement.

Utility relationships are critical to success. Utility programs can do a lot of technical research and put information together on specific topics, such as lab ventilation and lighting controls. Massachusetts encourages utilities to put forward code proposals as technical experts (either in-house or they can contract out for expertise). It is essential to harmonize with utilities around new construction incentive programs. Code and new construction programs work hand in glove to make it much easier for developers and builders to achieve the code

The utilities are effectively driving participation in HERS through incentive programs, as well as interest in passive house.

Potential savings are much larger for C&S adoption than for compliance improvement. There is a lack of common understanding that the potential savings from appliance standards is large. In California, more savings come from standards than codes in some years.

The evaluation method is similar to the typical evaluation protocol used for programs. It does, however, differ in asking key questions such as “what policy conflicts exist?” and “what is appropriate baseline?”

Having the evaluator involved in the program early on and providing insights about what would make the program valuable is critical to success. It requires documentation of what the program is doing in terms of technical assistance, research, and support to adopt a code.

The evaluation of codes differs from that of standards. Evaluation for national standards has to look across the national environment and into the process that the Department of Energy undertakes. In states that have the ability to adopt appliance standards, it is more similar to building code evaluation, but the significant difference is the potential for noncompliance in building codes. Noncompliance is much less of an issue in standards than in codes. Data availability is more of a challenge with appliances.

C&S is a statewide effort, even if it is delivered locally.

Several Minnesota utility entities operate in more than one state. Allowing program administrators to streamline their efforts will keep costs down for customers.

Minnesota should leverage the opportunity for program administrators to play different roles according to their strengths (i.e. municipal utilities will have closer ties to the local building department).

Minnesota has a lot of opportunity due to the significant, collective experiences from parties already interacting in the adoption of code, construction of buildings, and merchandising and sales of equipment to customers.

Minnesota only reports gross customer savings and is not accustomed to seeing net to gross values. Therefore, a successful approach would allow Xcel Energy to report something appropriate for a C&S product, while not disrupting the existing product ecosystem. A potential option is the use of a blended baseline. Minnesota could still report gross savings, but it would be adjusted to account for the naturally occurring rise in baseline. If Minnesota reached the consensus that a market transformation framework is fundamentally different from traditional resource acquisition CIP products, it could include an explicit attribution factor.

There are many conversations around codes taking place in Minnesota right now, so a key piece to the report will be to start weaving these conversations together to: Help inform those who are more engaged in CIP of what is happening outside of the programs (including the activities of the two working groups that are currently looking at the future of building codes). Fill in the gaps that have been identified across the different efforts in order to avoid duplicating work, while also making the best use of each stakeholder’s skillset and background.

It is one thing to get policy passed, but another to actually know that a state is achieving those savings.

It is important to get the evaluators involved early.

The consideration of both urban and rural communities is an important issue to Minnesotans. There is currently a hearing for Minnesota residential code adoption, where many stakeholders have spoken up about a lack of resources for rural customers. A consideration may be for other utilities to join in on this with the IOUs to create a statewide program. Minnesota could include weatherization assistance programs. If the Minnesota Energy Code Compliance Collaborate could be expanded to have more of a statewide focus, it could help distribute the resources across the entire state.