From Deemed Measure to Codes and Standards: A timeless idea that deserves a fresh look

Bryan Boyce, Energy Solutions, Andres Fergadiotti, Scott Higa, and Jay Madden, Southern California Edison


To meet aggressive greenhouse gas (GHG) reduction targets, technologies such as electric heat pumps must quickly be moved across the adoption curve. Exciting new CPUC policies like the fuel substitution test, tools like the electronic technical reference manual (eTRM), and the new total systems benefit (TSB) metric (which explicitly rewards GHG emissions reductions) provide an opportunity to significantly broaden the GHG-centered measures offered by Program Administrators (PAs). If Codes and Standards (C&S) programs were to become more directly involved with deemed eTRM entry development, then GHG savings could be even further maximized by providing program implementers with more incentive offerings and a quicker progression from incentive programs to C&S. These eTRM entries would be developed with a potential C&S pathway in mind up front. Although the adoption curve is a simplification of reality, it helpfully illustrates that measures tend to flow from emerging technology, to incentives, and eventually to codes and standards. In practice, the different programs can be siloed, which limits knowledge transfer between the market adoption bins. This paper will explore the opportunity of creating a framework where when appropriate, new measures consider the eventual codes and standards fate during their development. Specific examples will be detailed (such as a commercial unitary incentive program that leads to an appliance standard, or an air-to-water heat pump that becomes a code compliance credit). C&S measures have major GHG savings potential and the faster that all-electric designs can make their way into codes and standards, the more quickly that buildings will fully decarbonize.

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