Impacts of the 2021 WSEC on Industrial Facilities
The built environment accounts for about 40% of global carbon emissions. Reducing building industry emissions regionally is a cornerstone of Washington State’s plan for combating climate change. The 2021 Washington State Energy Code (WSEC) update is an ambitious and important step in reducing carbon emissions and improving building efficiency. The update touches all points of the building industryresidential and commercial, but this paper focuses exclusively on one specific slice: industrial buildings for manufacturing, warehouse, and logistics buildings that extensively utilize spaces classified as “semi-heated” (freeze protection only). Our takeaways can be summarized in four points: Fossil Fuels: There will be legislative uncertainty about the use, and degree of use, of fossil fuels for some time. However, the end goal is clear: they will be phased out in favor of electrification. Renewable Energy: Owners will need to install PV panels, or harness geothermal energy. Envelope, Electrical, and Mechanical Systems: New facilities will follow a scorecard to increase building performance, with choices on strategy made early in design. Washington Clean Building Performance Standard: This standard, separate from the Washington State Energy Code, directly impacts building owners, and needs to be taken into consideration alongside WSEC code requirements.
BACKGROUND Washington, like most states in the country, is in the process of adopting or have adopted the International Building Code (IBC) 2021. States have the latitude to amend the IBC and add other parameters. Washington State has developed its own energy code, the WSEC. Washington State has chosen to take a leadership role in fighting climate change. This effort has
been underway for decades. The State developed a long-term energy consumption program in 2006 with goals set for 2031. State mandate RCW 19.27A includes two key 2031 targets: a 70% reduction in net energy consumption; and 0% fossil-fuel greenhouse gas emissions. Code updates run on a 3-year cycle, and with each iteration performance standards are updated to meet this mandate. Corrections, adjustments, and lessons learned have been integrated in the Washington energy code revisions over the numerous updates. The City of Seattle has its own building and energy code, also on a 3-year update cycle. Traditionally, Seattle is one revision cycle ahead of the State code and provides a laboratory for the State in the direction of upcoming requirements. For example, in Seattle, fossil fuels were banned from most water and space heating systems in new construction by the 2018 City of Seattle code (SBC), adopted in 2021. An additional requirement for this building type is the Washington Clean Building Performance Standard, which was signed into law in 2019 and took effect in 2021, and initially affects commercial buildings over 50,000 SF. This standard is a separate effort and set of requirements, but strategies taken to comply with the energy code update will have a direct impact on compliance with the performance standard. We’ve organized this discussion into three categories: design impacts; build impacts; and operational impacts. The code rollout for the WSEC has been delayed because of litigation related to California Restaurant Association v. City of Berkeley, and as a result the code language will be evolving particularly around the use of natural gas. However, we can be confident that the end goal, and eventual legislation, will include a comprehensive transition away from fossil fuels. It would be wise to plan for this eventuality now. Impacts of the 2021 WSEC on Industrial Facilities v1.02
Page 2 Design: Previous iterations of the IBC required that roofs be “PV-ready”, and did not require installation. The 2021 code will require photovoltaic arrays to be installed on 40% of the roof area. Providing a renewable energy source is an integrated portion of the overall Washington State Energy Code framework. If a site supports a geothermal energy source, it can be used instead of PV panels. Build: PV Panels are required to generate 0.5 watts per square foot. This introduces additional roof penetration, increased frequency for roof access, and modifications to the electrical gear.
IMPACTS Fossil Fuel Ban The code update intends to ban the use of natural gas in most applications, including space heating for industrial freeze-protected facilities. This provision is the most contested, and will be modified or delayed. The exact language of the code is still being refined as of the writing of this brief. However, we believe a statewide adoption of such a ban is inevitable at some point.
Operate: Owners are being challenged with addressing the benefits from on-site power generation and impacts or pass-throughs to tenants. Tenants are receiving corporate benefits resulting from facilities being partially powered by a renewable energy source.
The ban may be achieved by it becoming very difficult to comply with the energy code without deploying other more expensive strategies. It has been a reality in Seattle since March 15, 2021. Design: Currently, gas fired space heaters are utilized in semi-heated facilities, and the buildings are designed with R-38 roof insulation and no wall insulation. Without gas heaters a heat-pump solution will be the only alternative, and all walls in semiheated facilities will need full wall insulation. Build: A heat-pump solution is a rooftop unit providing forced air for heating and ventilation. This, coupled with new wall insulation requirements, will present a significant cost. Operate: The goals of a zero-fossil fuel solution will be met. The maintenance costs of these units will be higher than a gas-fired unit heater. Conversion to provide cooling is possible with subsequent modifications. The resulting thermal comfort will be noticeably increased due to wall insulation and the heat-pump system, while energy costs will be greater.
EV Charging A state amendment to the IBC 2021 brings an increase from 5% to 30% to the quantity of parking spaces with some level of EV charging infrastructure. Previously, a project needed to provide 5% stall with EV charging infrastructure (no wire and no chargers). Design: With this amendment a 3-tiered system is required. 10% stall wired with chargers (required), and an additional 10% wired (ready), and a further 10% with conduit infrastructure (capable).
Renewable Energy
Build: The construction aspects are not significant. The challenge today is the availability of electrical power capacity available from the local utility.
A state amendment to the IBC 2021 brings an impact to roofs with a requirement to install photovoltaic (PV) panels. The 2021 code update will require photovoltaic arrays to be installed on 40% of the roof area. Earlier iterations required that roofs be PV-ready, and did not require installation.
Operate: Owners will need to decide whether to own and operate the chargers, the type of charger, and whether to lease or subcontract the chargers. Some owners are placing EV chargers on sub-meters to track electrical costs and whether and how to charge users.
Mackenzie November 2023
Page 3
Envelope, Electrical, and Mechanical Systems Choices WSEC impacts numerous systems and design elements. Design: The concept of a scorecard/point system has been present in design and construction with the LEED Green Building System for over a decade. With this new version of the WSEC a similar system is introduced. Additional Energy Efficiency and Load Management Measures Credit Requirements. Buildings are required to define how a minimum number of credits are obtained in the design and its systems. The owner, architect, contractor, and MEP engineer will participate in evaluating what points to select for a compliance path. Like the LEED system, this needs to happen early on and really cannot be defined at the end of design. There are currently 31 different options to choose from. All are measures that are beyond the prescriptive choices available to increase the performance of the building. Some are not available in all types of commercial buildings, i.e. laundry equipment. In speculative developments, energy profiling will be similar to other design challenges where the end user is unknown. Build: The systems, construction elements, costs, and testing all yield increased project costs. Some also offer additional risks. Operate: These measures should result in lower energy costs to the owner.
The act establishes a Clean Buildings Performance Standard (BPS) for commercial buildings that are 50,000 square feet or larger. The BPS requires these buildings to meet certain energy efficiency targets based on their size and type. Buildings that do not meet the BPS will be required to implement energy efficiency measures to bring their energy use down to the target. The first phase of the act, which requires benchmarking and reporting for Tier 1 buildings, began on July 1, 2021. The second phase of the act, which requires compliance with the Clean Buildings Performance Standard for Tier 1 buildings, will begin on July 1, 2026.
Conclusion Owners of semi-heated industrial facilities will see WSEC impacts in an eventual fossil fuel ban; expanded renewable energy requirements; expanded EV requirements; and scorecard-type requirements for the envelope and mechanical systems. These requirements will need to be engaged in parallel with the Clean Buildings Performance Standard.
Author Daylighting The WSEC code has included provisions for skylights for many years. The 2021 version did not change this requirement, but it remains an important component of the overall energy performance of a facility.
Washington Clean Building Performance Standard This is an entirely new high performance building requirement for owners. The Washington Clean Buildings Act (HB 1257, 2019) was signed into law in May 2019. The legislation aims to reduce energy consumption and greenhouse gas emissions from commercial buildings in Washington state.
Brett Conway, AIA, NCARB, LEED AP Architect | Associate Principal Mackenzie
Contributors Chris McAlevy, EIT Mechanical Designer/Commissioning Agent Interface Engineering Bryan Galvin Vice President Universal Refrigeration Fore more information, please contact Brett Conway: bconway@mcknze.com Impacts of the 2021 WSEC on Industrial Facilities v1.02