**The Washington State Energy Code:**

**The Residential Code Monitoring**

**Program**

**by**

**John Devine**

Washington State University

Cooperative Extension Energy Program

Prepared under an Exemplary Award

for the U.S. Department of Energy's

Building Standards and Guidelines Program

![](media/image1.emf){width="3.798611111111111in"
height="0.7597222222222222in"}

January 1997

WSU/EEP 97-006

This case study is one in a series documenting successful building
energy code programs for use by other states as technical assistance
models in support of the U.S. Department of Energy (DOE) Building
Standards and Guidelines Program.

The primary issue addressed by the Program (and other programs at DOE)
is that new commercial and residential buildings being designed, built
and occupied do not use currently available, technically feasible, and
economically justified technologies and practices to eliminate the
wasteful use of energy. The Program seeks to advance the
energy-conserving design and construction of buildings by promoting and
assisting the development and implementation of energy efficient codes
and standards that are technically feasible, economically justified and
environmentally beneficial. These activities are required of DOE by
Title III of the Energy Conservation and Production Act as amended by
the Energy Policy Act of 1992 (EPACT). The long-term goal of the Program
is to make sustainable, energy-efficient building design and
construction common practice.

The Program's approach to meeting this goal is to initiate and manage
individual research, standards and guidelines development efforts that
are planned and conducted in cooperation with representatives from
throughout the buildings community. Current projects involve practicing
architects and engineers, professional societies and code organizations,
industry representatives, and researchers from the private sector and
national laboratories. Research results and the technical justification
for standards criteria are provided to standards development and model
code organizations and to federal, state and local jurisdictions as a
basis to update their codes and standards. This approach helps to ensure
that the standards incorporate the latest research results to achieve
maximum energy savings in new buildings, yet remain responsive to the
needs of the affected professions, organizations and jurisdictions. It
also assists in the implementation, deployment and use of the codes and
standards.

Eric Makela Margo D. Appel

Pacific Northwest National Laboratory U.S. Department of Energy

Table of Contents

Table of Figures

Acknowledgments

Executive Summary

Introduction: What is the Washington State Energy Code?

Energy Code Administration

Historical Perspective

The Energy Code in Action - Who Does What

Development of the Monitoring Program

The Washington State Energy Code Program

The Monitoring Plan

Proponents and Opponents of Code Compliance Monitoring

Development of Methodology

The Ten Measures

Monitoring in Practice

Year One

Years 2 - 4

Scores and Technical Findings

Slab Insulation

Wall Insulation

Fenestration

Ceiling Insulation

Floor Insulation

Duct Insulation and Sealing

Air Leakage Control

Ventilation Systems

Radon Requirements

Solid Fuel Combustion Appliances

Plan Review

Success of the Program

What do the Scores Tell Us?

What did the Monitoring Process Accomplish?

Lessons Learned

Conclusion

Bibliography

Appendix - Monitoring Checklist

#   {#section .unnumbered}

# Table of Figures

Figure 1: Chronology of Major Energy Code Efforts in Washington State

Figure 2: Responsibilities for Functions of the Washington State Energy
Code

Figure 3: Comparison of Code Compliance Deviations for Program
Participants and non-Participants

Figure 4: Code Compliance Deviations for All Measures

Figure 5: Code Compliance Deviations for Slab Insulation Versus all
Other Measures

Figure 6: Code Compliance Deviations for Wall Insulation Versus all
Other Measures

Figure 7: Code Compliance Deviations for Fenestration Measures Versus
all Other Measures

Figure 8: Code Compliance Deviations for Ceiling Insulation Versus all
Other Measures

Figure 9: Code Compliance Deviations for Floor Insulation Versus all
Other Measures

Figure 10: Code Compliance Deviations for Duct Insulation and Sealing
Versus all Other Measures

Figure 11: Code Compliance Deviations for Air Leakage Control Versus all
Other Measures

Figure 12: Code Compliance Deviations for Wall Ventilation Systems
Versus all Other Measures

Figure 13: Code Compliance Deviations for Radon Requirements Versus all
Other Measures

Figure 14: Code Compliance Deviations for Solid Fuel Combustion
Appliances Versus all Other Measures

Figure 15: Code Compliance Deviations for Plan Review Versus all Other
Measures

# Acknowledgments

This project was awarded through an Exemplary Grant funded by the U.S.
Department of Energy's (DOE) Building Standards and Guidelines Program.
Pacific Northwest National Laboratories (PNNL) heads the program for
DOE. The project benefitted from direction and oversight provided by the
project manager, Eric Makela, PNNL. The author is grateful for his
support.

In addition, the author acknowledges the insightful comments provided by
his colleagues at the Washington State University Cooperative Extension
Energy Program - Rick Kunkle, Bruce Carter, Tony Usibelli, and Karen
Messmer.

The other related case studies regarding the Washington State Energy
Code, prepared under the DOE Exemplary Grant, are:

-   [The Washington State Energy Code: Training and Publication Support
    for the Residential Code]{.underline}, by Bruce Carter

-   [The Washington State Energy Code: The Role of Evaluation in
    Washington State's Non-Residential Energy Code]{.underline}, by Tony
    Usibelli

-   [The Washington State Energy Code: Energy Code Privatization - The
    Utility Code Group Story]{.underline}, by Rick Kunkle

-   [The Washington State Energy Code: Certification for Inspectors and
    Plan Reviewers for the Non-Residential Energy Code]{.underline}, by
    Rick Kunkle

This and the other Washington State case studies were edited and
prepared by Andrew Gordon, Washington State University Cooperative
Extension Energy Program.

# Executive Summary

On July 1, 1991, Washington State began enforcing the requirements of an
energy code based on the Model Conservation Standards. The Washington
State Energy Office, a non-regulatory state agency, was awarded the task
of providing support for the new code.

The Washington State Energy Code Program provided financial and
technical support to ensure the successful implementation of the 1991
Washington State Energy Code. A cornerstone of the code was the
Monitoring Program, designed to provide feedback on code compliance. The
Monitoring Program was developed with input from the shelter industry,
code officials, utilities and all levels of government.

The methodologies utilized in code compliance data collection were not
highly scientific. Instead, the approach to data collection mirrored the
building inspection process. Many code requirements are qualitative and
therefore the data analysis is not based upon objective certainty.
However, since the monitoring process and staff were consistent
throughout the program, relative compliance levels are measurable over
the four year data collection period.

The Monitoring Program was a useful vehicle in disseminating technical
information to builders, code officials, code trainers, and technical
assistance providers. Data collection was not an end in itself; the
primary purpose of the Program was to provide on-site code technical
assistance. The monitoring process had a positive and direct effect on
overall compliance.

Analysis of the data shows that compliance improved steadily during the
four year period of data collection. A third party analysis of
residential energy code compliance in Washington State concludes that
the code is providing energy savings.

The general methodology of data collection and technical assistance used
for the Monitoring Program can be utilized by other entities, if
increased code compliance is the desired result.

# Introduction: What is the Washington State Energy Code?

The Washington State Energy Code provides energy efficiency standards
for new and altered residential and commercial buildings in Washington
State.[^1] The first Washington State Energy Code appeared in 1978;
since then, it has been revised in light of advances in building science
and new energy efficient technologies.

The current versions of the Washington residential and non-residential
energy codes were implemented in 1991 and 1994, respectively. The state
legislature passed a bill in 1990 that upgraded energy codes for
residential structures; in 1991, the legislature authorized the State
Building Code Council to upgrade the energy code for non-residential
structures.

## Energy Code Administration

In Washington State, the legislature is given the authority to revise
building codes, including the Energy Code. The State Building Code
Council administers the building code and ensures that the state's
interests are met according to state law. The Council includes
representatives from the building industry, local government, and code
enforcement officials. Building codes are enforced by local
jurisdictions. Cities and counties have building departments with code
officials who conduct plan reviews and building inspections. Enforcement
is funded at the local level.

## Historical Perspective

The Washington State Energy Code did not appear in its present form
overnight. The current code is the result of a gradual process over a
period of sixteen years. **Figure 1** presents a chronology of major
events and efforts leading up to the current code.

**Figure 1**

**Chronology of Major Energy Code Efforts in Washington State**

## The Energy Code in Action - Who Does What

The successful functioning of both the residential and non-residential
energy codes are due to participation by a number of different entities.
**Figure 2** outlines the functions provided by the various agencies and
associations as of December 1996.

**Figure 2**

**Responsibilities for Functions of the Washington State Energy Code**

![](media/image4.emf)**Key**

SBCC State Building Code Council

WSU Washington State University Cooperative Extension Energy Program -
formerly the Washington State Energy Office

CTED Washington State Department of Community Trade and Economic
Development

SPE/I Special Plans Examiners and Inspectors

UCG Utility Code Group - Typically acting through subcontractors

# Development of the Monitoring Program

## The Washington State Energy Code Program

The Bonneville Power Administration funded the evolutionary product of
the Northwest Energy Code - the Washington State Energy Code Program.
The program was created to offer local governments assistance in
implementing and enforcing the code. Local jurisdictions were required
to enforce the energy code through inspections, and work with the
Washington State Energy Office on evaluation activities. In turn, the
jurisdictions received financial incentives, training and technical
assistance.

Unlike the Northwest Energy Code, all jurisdictions were required to
enforce the Washington code, whether or not they chose to participate in
the Code Program. Also, Northwest Energy Code compliance was closely
tied to contract payments, whereas the state code contract payments were
more closely tied to participation in training and technical assistance.
This approach to code compliance was consistent with the Washington
State Energy Office's mission as an agency. The office was never charged
by law to act as a regulatory agency, and never attempted to enforce the
code through the Program. Rather, it used its advisory role as a
marketing tool to stave off local government's fears of state
interference.

## The Monitoring Plan

Included in the Program was the Monitoring Plan, which contained some of
the elements of the Northwest Energy Code monitoring effort. The primary
similarity between the two monitoring plans was the "construction phase"
approach. Both plans monitored structures during the construction phase,
rather than after completion.

## Proponents and Opponents of Code Compliance Monitoring

Although the importance of monitoring the performance of any large
project may seem apparent, not all the players in the Washington State
Energy Code Program were enthusiastic participants in this aspect of the
Quality Assurance Plan. The Bonneville Power Administration was the
primary proponent of code compliance monitoring. Bonneville's interest
in measuring the success of the Monitoring Program is understandable;
after all, they were about to fund the most expensive statewide energy
code effort in the nation. Likewise, the utilities served by Bonneville
wanted compliance monitoring. On the other side of the coin were the
people whose work was to be judged: the builders, code officials, and
the Energy Office.

Although the builder organizations were invited to participate in the
development of the Quality Assurance Plan, they did not do so.
Representatives from the Energy Office met with the Building Industry
Association of Washington on several occasions in 1991 and early 1992 to
encourage greater builder participation, but the Association was either
disinterested, or perhaps too understaffed to provide input. Also
possible, however, is that the Association wanted nothing to do with the
Code Program, so they were expending their resources to eliminate the
code completely. The Association's lack of input was a surprise to
Energy Office staff, who assumed builders would be very concerned about
the state's role in code compliance. The Energy Office's goal in meeting
with the Builder's Association was to assure them that the Energy
Office's presence at a job site did not constitute "double jeopardy" and
that the actual inspection process was the domain of the local
inspector.

The builders' apathy to the Monitoring Plan stood in stark contrast to
the position of code officials. The Washington Association of Building
Officials emphasized its members' exclusive right to deem a structure as
compliant to most building codes - including the Energy Code. Some
building officials and Association members felt the Code Program allowed
the state to usurp authority that rightfully belonged to local
governments. In a survey by the Association of Washington Cities,
non-participants cited compliance monitoring as one of the main
disincentives to participating in the Program.

A compromise was reached: a first year grace period where the Energy
Office agreed not to collect data, but still conducted on site technical
assistance. The grace period allowed building officials and builders
time to learn the Code without suffering the embarrassment of being
judged by the Energy Office. The Energy Office supported the idea of
this grace period, because low compliance, even in the early stages of
the Program, could have provided detractors with ammunition to scrap the
Code as "unenforceable". Unfortunately, this decision seriously
undermined the effort to quantify the effect of the Program on overall
Code compliance. (See **Lessons Learned**.)

The Energy Office viewed implementation of the Monitoring Program as a
task in diplomacy. On one hand, the Energy Office did not want a program
if it presented a marketing liability. On the other hand, it needed a
tool that would provide feedback to code trainers as well as to
Bonneville. The mission the Energy Office faced was a balancing act.
They wanted to make sure Bonneville was confident in their ability and
sincerity about monitoring; but did not want to appear as if they were
enthusiastically snatching authority from the code enforcement
community.

## Development of Methodology

To a great extent, the development of the Monitoring Plan was narrowed,
at least initially, by the scope of the Energy Code Program. The plan
was only to apply to Energy Code Program jurisdictions, since
non-participating jurisdictions expressed discomfort with the process.
Only electrically heated homes would be monitored, because the Program
was funded by Bonneville. (Later, some of these limitations were
removed. See **Monitoring In Practice**.)

During the first year of the Energy Code Program, no code compliance
monitoring data was collected. Instead, on-site technical assistance was
provided at the initiative of the Energy Office. Although cooperation
with technical assistance and monitoring site visits was a Program
contract requirement, participants were treated as valuable customers.
Energy code staff from the Energy Office contacted participating local
building officials, reminded them of contractual obligations, assured
them that the visits were confidential and made appointments. On-site
technical assistance generally included an energy code plan review of a
current project in the presence of a code official. After the plan
review, several sites were visited, chosen by the building official.
While on site, questions about specific code requirements were gathered
and discussed with builders and code enforcement personnel.

Technical assistance providers from the Energy Office periodically
shared notes, and over time, ideas for systematically collecting data
emerged. A wide range of ideas were proposed and rejected. One approach
proposed the use of measuring tools like flowhoods and blower doors to
precisely measure a comprehensive list of code requirements. At the
other end of the spectrum, a plan was proposed for a subjective analysis
of only one or two code measures per year.

A limiting factor in deciding the approach to monitoring was access to
the sites. Building departments generally only have access to a site
until the final inspection. This presented a problem for conducting air
leakage tests, which could only be accurately done after the structure
was completed. An additional problem with conducting air leakage tests
is that they did not measure code compliance directly, since air leakage
control requirements are prescriptive. (A method to meet performance air
leakage requirements is available in the systems analysis approach, but
was never encountered in the field by monitoring staff.) In other words,
it might be possible to air seal according to prescriptive requirements,
but still not meet performance standards. Lastly, blower door tests are
time consuming, and only a very small sample of blower door tests could
be conducted without stretching Program resources and creating
additional tensions between building officials and the Energy Office.

Eventually, the Quality Assurance Group settled on a plan where seven
Energy Code requirements, two Ventilation and Indoor Air Quality Code
requirements, and one programmatic requirement would be measured for
"code acceptance." The term "code acceptance" was adopted because code
officials were uncomfortable with the underlying assumption that they
might provide Certificates of Occupancy for structures that did not
comply to code.

## The Ten Measures

The measures selected for the Monitoring Program were:

-   floor insulation

-   wall insulation

-   ceiling insulation

-   duct insulation (and sealing)

-   air sealing

-   fenestration

-   slab insulation

-   plan review

-   mechanical ventilation

-   radon requirements (replaced in 1993 by solid fuel burning appliance
    requirements.)

Plan review was selected at the urging of utility representatives who
had experience in enforcing the requirements of voluntary incentive
programs, like Super Good Cents. The utility representatives were
adamant that a great number of enforcement problems could be avoided if
caught in the plan review process. This was also an opportunity for the
Energy Office to monitor program compliance; jurisdictions were
required, by contract, to fill out and file inspection checklists for
each job. Also, since many homes complied via the component performance
approach, a review of the plans was needed to determine the level of
Code acceptance (the component performance approach allows trading off
the thermal efficiency of one building component for another, using a
higher level of attic insulation to allow for less wall insulation, for
example.) If the file had inadequate detail to determine the
requirement, (for example, the required R-value of insulation) it was
assumed that the building official, and perhaps the builder, also did
not know the requirement.

Mechanical ventilation and radon requirements were selected because they
were desired for inclusion by Bonneville. All funding for the Energy
Code Program was based upon the codes meeting Bonneville's Record of
Decision for Indoor Air Quality. The Bonneville decision forced
Washington State to adopt the Ventilation and Indoor Air Quality Code
along with the Energy Code, if federal funding was to be provided for
the program. The key elements of the Ventilation Code related to radon
resistive construction and to whole house mechanical ventilation. (A
1993 change in Bonneville's Record of Decision led to the removal of the
radon requirements in favor of solid fuel burning appliance
requirements. Each of these Ventilation Code measures were monitored for
two years.)

In addition to a monitoring checklist, a glossary was developed that
defined levels of "code acceptance." To ensure uniform data collection,
definitions of a perfect score, a minor variance, a serious variance,
and a very serious variance were developed for each of the ten measures
monitored. The monitoring checklist and definitions were the tools the
code monitoring staff used to collect and score field data. (See
**Appendix** for a copy of the monitoring checklist.)

# Monitoring in Practice

## Year One

On July 1, 1992, the Washington State Energy Code Monitoring Program
officially began. Once actual data collection began, the monitoring
staff quickly realized that scoring measures for code were very
subjective. Code language was used as the standard; in practice however,
the code was often too simplistic to use as a benchmark for assessing a
[degree]{.underline} of compliance. For example, according to the code,
"*To the maximum extent possible, insulation shall extend over the full
component area to the intended R-value."* The question arises, "what is
the maximum extent?" Opinions about quality and code requirements varied
widely among builders, building officials and even the monitoring staff.
After three months of data was collected, it was found that the average
scores varied widely, depending on who collected the data. Some of these
issues were resolved through discussions and joint visits, where each of
the monitoring staff independently collected data at several sites and
shared notes and scores afterward. As a result, some of the scoring
definitions were firmed up to narrow the effect of subjectivity.
Nevertheless, throughout the monitoring period, variances in scores can
be partially attributed to the scorekeepers, rather than to differences
in site conditions.

Pacific Northwest National Laboratories (PNNL) was assigned the task of
providing perspective on code compliance levels. As part of their study,
they shadowed the monitoring process over a few months and collected
data. They found that the monitoring reports tended to
[under]{.underline}estimate the level of compliance. PNNL typically
found higher compliance levels than did the Energy Office - even where
both parties monitored the same site. After achieving a high level of
confidence in monitoring data, PNNL settled on data supplied directly
from the Energy Office monitoring database for its study. Prior to
releasing their report, PNNL made recommendations designed to improve
the quality of the data. They suggested a more detailed data collection
form designed to reduce subjectivity. In the second year of data
collection, a new form was introduced based on PNNL's recommendations.

## Years 2 - 4

The second year of code monitoring included gas heated homes located in
Program jurisdictions. Although local building departments were not
obligated by contract to facilitate data collection at these sites, none
objected. The advantage of collecting data at these sites was related to
ventilation code requirements. Since almost all of the electrically
heated homes on the west side of the state utilized ductless heating
systems, the whole house ventilation strategies that were integrated
with the ducted systems were not adequately monitored during the first
year.

In Year Three, the Energy Office began monitoring jurisdictions that
were not participants in the Program. The advantage in including
non-participants is that it allowed the Energy Office to compare Program
jurisdictions to non-participants. So, by Year Three of the Program,
virtually all residential sites could be monitored for code compliance,
so long as the Energy Office could gain access from either the Building
Official or the builder. **Figure 3** provides a comparison of Program
participants to non-participants.

**Figure 3**

**Comparison of Code Compliance Deviations for Program Participants and
non-Participants**

![](media/image5.emf)

The Energy Office had a great deal of success in monitoring sites that
were not electrically heated. Throughout the Program, gas utility
service expanded to more areas of Washington State. In fact, some
jurisdictions quit the Program because they lacked electrically heated
sites.

Code monitoring in non-Program juridictions was more difficult.
Typically, jurisdictions were recruited for monitoring when they called
for assistance on the Energy Code Hotline. Several jurisdictions were
monitored with the assistance of cooperative builders, whose sites were
also recruited via the Hotline. While the Energy Office did not monitor
as many non-Program sites as desired, they managed to monitor some sites
in all of the major non-Program jurisdictions.

## Scores and Technical Findings

A simple analysis of the data quickly reveals one obvious, irrefutable
fact: code compliance improved over time. For the first two years of the
study, scores improved steadily during each three month period. Over the
four year program, each year's scores were an improvement over the
previous year. **Figure 4** shows the average level of compliance for
all code measures over time.

**Figure 4**

**Code Compliance Deviations for All Measures**

![](media/image6.emf)

The following subsections break down compliance levels for each of the
ten measures compared to all other measures.

**Note:** Nearly all code requirements can be "traded-off" through a
component performance or systems analysis approach (the systems analysis
approach encompasses the trade-offs allowed in the component performance
approach, but includes allowances for solar gain and heating,
ventilation and air conditioning (HVAC) efficiencies.) The component
performance approach allows for insulation to be decreased in one area
of a building, as long as the overall efficiency of the structure meets
code requirements. About half of the residential structures in this
study used "trade-off" calculations to prove code compliance.

### Slab Insulation

**Requirement**: The perimeter edge of an on grade concrete slab is
required to be insulated from the top of the slab downward for 24,\" or
to the footing, whichever is less. The Prescriptive Approach requires
R-10 insulation.

**Analysis**: A total of 148 sites were monitored for these
requirements. Most non-complying on-grade slabs lacked insulation
between the garage concrete (or patio) and the interior space. This was
the poorest scoring measure during the first year, as it was not
standard practice prior to the 1991 Energy Code. Data shows that
compliance improved dramatically over the monitoring period, possibly
because the builders learned to trade-off the slab insulation
requirement via the component performance approach. **Figure 5**
provides a comparison of slab insulation compliance versus all the other
measures.

**Figure 5**

**Code Compliance Deviations for Slab Insulation Versus all Other
Measures**

![](media/image7.emf)

### Wall Insulation

**Requirement:** Exterior walls must be insulated. Insulation must be
installed according to manufacturer\'s instructions to achieve proper
densities and maintain uniform R-values. Insulation R-values vary based
on weather zone and compliance approach.

**Analysis:** A total of 326 sites were monitored for these
requirements. Scoring for this measure was more subjective than most
other measures. The monitoring staff had to judge when the insulation
was more compressed than necessary. The scores were good, but erratic
over the 4 year period. Nearly all the homes had the appropriate R-value
installed. **Figure 6** provides a comparison of wall insulation
compliance versus all the other measures. There is no technical
explanation for the decrease in compliance in Year 3. This aberration is
small for such a subjective measurement.

**Figure 6**

**Code Compliance Deviations for Wall Insulation Versus all Other
Measures**

![](media/image8.emf)

### Fenestration

**Requirement:** Properly labeled doors and windows (of appropriate
U-value) must be installed. The U-value requirement varies from .75 to
.28, depending on glazing area, compliance approach, zone, and fuel
type.

**Analysis:** A total of 888 sites were monitored for these
requirements. This was the best scoring measure. When a score was less
than perfect, it was generally because the contractor removed the
U-value labels prematurely. The scores worsened slightly in the last
year of the program, primarily due to an Energy Code amendment requiring
that American Architectural Manufacturer's Association labels be
replaced with the more stringent National Fenestration Rating Council
(NFRC) labels. **Figure 7** provides a comparison of fenestration
compliance versus all the other measures.

**Figure 7**

**Code Compliance Deviations for Fenestration Measures Versus all Other
Measures**

![](media/image9.emf)

### Ceiling Insulation

**Requirement:** Ceilings must be insulated, typically to R-38.
Insulation must be installed according to manufacturer\'s instructions
to achieve proper densities and maintain uniform R-values.

**Analysis:** A total of 153 sites were monitored for these
requirements. Monitoring staff had to judge when it was compressed, or
improperly blown, or in the path of ventilation air. The scores were
poor the first year, and somewhat erratic over the 4 year period,
largely due to the subjective nature of the scoring. Even in the worst
cases, most of the required insulation was installed. **Figure 8**
provides a comparison of ceiling insulation compliance versus all the
other measures.

**Figure 8**

**Code Compliance Deviations for Ceiling Insulation Versus all Other
Measures**

![](media/image10.emf)

### Floor Insulation

**Requirement:** Floors over unconditioned spaces must be insulated over
the full component area, in a permanent manner, in contact with the
surface to be insulated, and without compression. Typical insulation
levels were R-30 for electrically heated homes and R-19 for homes heated
by other fuels.

**Analysis:** A total of 265 sites were monitored for these
requirements. This was the worst scoring measure in three of the four
years of monitoring. Several problems contributed to the poor scores.
Frequently, insulation was found to be supported by spring loaded rods,
that at best, compressed the insulation, and at worst, fell out and
allowed the insulation to sag. When twine was used to support the
insulation, particularly where truss-joist I-beams were used, the twine
was not installed so that the insulation remained in contact with the
floor. Where R-19 insulation was allowed, twine was often stapled to the
bottom edge of the 10" joist, so that the insulation was suspended two
inches below the underside of the floor. Technical assistance and
training staff focused on this problem and offered solutions. As a
result, during the last year of monitoring, many insulation contractors
used inset stapling with the twine, and scores dramatically improved.
**Figure 9** provides a comparison of floor insulation compliance versus
all the other measures.

**Figure 9**

**Code Compliance Deviations for Floor Insulation Versus all Other
Measures**

![](media/image11.emf)

### Duct Insulation and Sealing

**Requirement:** Ducts in unconditioned areas shall be insulated and
sealed. Typically, ducts must be insulated to R-8, and joints must be
sealed with a material approved by the building official.

**Analysis:** A total of 194 sites were monitored for these
requirements. The scores for duct insulation and sealing were average
and relatively static throughout the monitoring period. During the third
year of monitoring, Energy Office staff were aware of a study that
showed duct leakage can account for about 30 percent of a home\'s heat
loss, and scrutinized ducted heated systems more closely. Intense visual
inspections of ducts did not corroborate with more technical studies
that measured actual duct leakage. This finding may be significant: if
technicians trained specifically in energy conservation could not find
the duct leaks, certainly local code inspectors would have similar
difficulties. **Figure 10** provides a comparison of duct insulation and
sealing compliance versus all the other measures.

**Figure 10**

**Code Compliance Deviations for Duct Insulation and Sealing Versus all
Other Measures**

![](media/image12.emf)

### Air Leakage Control

**Requirement:** Seal air leaks through the building shell.

**Analysis:** A total of 542 sites were monitored for these
requirements. The requirement sounds simple but the potential for a
contractor to miss some leaks is practically 100 percent. All leaks
through the shell were considered variances with the code requirement.
Monitoring staff looked for groups of variances (for example, window
frames, electrical outlet boxes and plumbing penetrations would each be
considered a separate group.) If leaks were found in three or more
groups, the job was considered seriously flawed.

The scores for air leakage control remained static throughout the
Program, and a little worse than average compared to other measures.
Bypasses were consistently found through ceiling fixtures and also in
the rim joist between floors of two story homes. Both the rim joist and
ceiling fixture leaks were often overlooked entirely by the air sealing
contractor. These areas are too high to seal without using a ladder.
Additionally, air sealing electric boxes were sometimes overlooked
entirely. Other deficiencies were found more sporadically. **Figure 11**
provides a comparison of air leakage control compliance versus other
measures.

**Figure 11**

**Code Compliance Deviations for Air Leakage Control Versus all Other
Measures**

![](media/image13.emf)

### Ventilation Systems

**Requirement:** All bathrooms, laundry areas, and kitchens must be
provided with exhaust fans that are ducted outdoors. All homes must have
whole house mechanical ventilation that is either continuous, or
intermittently controlled and capable of providing .35 to .50 air
changes per hour.

**Analysis:** A total of 752 sites were monitored for these
requirements. The "source" exhaust fan requirement was rarely violated,
except in kitchens where recirculating exhaust hoods were sometimes
found. Ventilation systems for homes with ductless heating systems
typically met requirements, but occasionally, through the wall (or
window frame) air inlets were not installed. Ventilation systems that
utilized the heating system ducts to distribute fresh air (called
integrated systems) frequently had compliance problems, primarily
because some options have *performance* requirements that are
*prescriptively* required. During monitoring visits, it was found that
few systems were actually performance tested, or at least, no
documentation could verify tests. The systems encountered in the field
were often ineffective marriages of several different compliance
options; some systems exceeded code requirements but most led to severe
over-ventilation, lack of control, or under-ventilation in the bedrooms.
**Figure 12** provides a comparison of ventilation system compliance
versus all the other measures.

**Figure 12**

**Code Compliance Deviations for Wall Ventilation Systems Versus all
Other Measures**

![](media/image14.emf)

### Radon Requirements

**Requirements:** A radon detector must be on site at final inspection;
and radon mitigation strategies must be fully or partially installed for
some geographic areas and types of construction.

This indoor air quality measure was only studied for two of the four
years.

**Analysis:** A total of 42 sites were monitored for these requirements.
During the first year of the study, the average score was worse than for
any measure. During the first year, builders were required to leave a
radon detector at the job site, but often failed to do so. The scores
improved dramatically during the second year, as the radon requirements
became more well known and accepted. **Figure 13** provides a comparison
of radon requirement compliance versus all the other measures.

**Figure 13**

**Code Compliance Deviations for Radon Requirements Versus all Other
Measures**

![](media/image15.emf)

### Solid Fuel Combustion Appliances

**Requirements:** Most solid fuel combustion appliances are required to
be directly connected to an outside combustion air source and have tight
fitting glass doors. Wood stoves, fireplaces and pellet stoves are
examples of this type of appliance. This measure was studied in the
third and fourth years of the Program.

**Analysis:** A total of 81 sites were monitored for these requirements.
Scores for these requirements were excellent during both years. Calls on
the Residential Hotline indicate that these requirements were more
problematic for existing construction. **Figure 14** provides a
comparison of solid fuel combustion appliance compliance versus all the
other measures.

**Figure 14**

**Code Compliance Deviations for Solid Fuel Combustion Appliances Versus
all Other Measures**

![](media/image16.emf)

### Plan Review

**Requirements:** Accurate documentation should exist on file that shows
the structure meets Energy and Ventilation codes. Required documentation
includes an inspection checklist, compliance calculations, and
blueprints.

**Analysis:** A total of 500 sites were monitored for these
requirements. The scores for plan review improved steadily, but not
overwhelmingly, over the four year period. It was found that poor
documentation did not often translate into poor compliance in the field.
Nearly all job files contained some information about the energy code,
though detail was often lacking. The increase in deviations in Year Two
is probably due to a more detailed monitoring scoresheet, which provided
more detail than the scoresheet used in Year One. **Figure 15** compares
plan review compliance versus all the other measures.

**Figure 15**

**Code Compliance Deviations for Plan Review Versus all Other Measures**

![](media/image17.emf)

# Success of the Program

## What do the Scores Tell Us?

The PNNL study suggested that the scores can be translated into actual
energy saved by the code. The Energy Office contended that the purpose
of the monitoring study was threefold: to provide on-site technical
assistance, to collect information for use in training, and to help
determine whether or not compliance levels improved during the program.
Using only the data collected in the first year, PNNL suggested that the
energy saved was about 95 percent of what could be expected from full
compliance. However, other studies showed that air leakage in Energy
Code compliant homes, particularly those with ducted heating systems,
was much higher than levels that could be predicted using monitoring
data.

## What did the Monitoring Process Accomplish?

First, the monitoring process provided direct feedback to builders. A
key element of the monitoring process was the on-site technical
assistance that occurred spontaneously during the visit. Often, the
contractors were eager to participate and asked questions on site.
Although a few builders were hostile or indifferent, the vast majority
of the builders (general and subcontractor) wanted to know how well they
scored. When a problem was found, the builders sometimes became
defensive, but when presented with accurate reasoning for the code, and
given a choice of acceptable compliance methods, they were typically won
over.

The monitoring process also provided feedback and instruction to the
code officials. Many code officials see themselves as contributing to
the building process rather than merely enforcing the law. If they do
not understand the reasoning behind the code, they can be embarrassed by
a builder who challenges requirements. The code monitoring staff was
very adept at explaining the scientific foundation of the Energy Code.
Customer service oriented building officials need this information to do
their jobs well.

The monitoring process also provided feedback to Energy Office code
staff. Difficulties encountered in the field resulted in training
sessions that were more focused and Hotline advice that was more
pertinent. When truss joist I-beams became a common building component
during the second year of the program, monitoring staff alerted trainers
and Hotline staff of the related floor insulation deviation (see **Floor
Insulation**.) In the field, builders and inspectors were advised of any
problems encountered. By the fourth year of the monitoring program,
nearly all floor insulation jobs were done properly, and the scores
dramatically improved.

# Lessons Learned

-   The data collected may have been more useful if the scores ranged
    from 1 to 10 rather than just 1 to 4. Perfection is a difficult and
    very subjective goal. The scale using (1 - 4, where one is perfect
    and four is very poor) tended to cause the Energy Office staff to
    select "2" as the appropriate rank for even slight quality problems.
    More gradations in the scale would help to assess the magnitude of a
    problem more accurately.

-   The total number of sites monitored is less important than the
    number of enforcement staff and contractors participating in the
    process. When the requirements of the code are explained well from a
    building science perspective, they are more likely to be accepted by
    builders and code officials. One-on-one assistance of this type is
    challenging, but effective. Individuals who came to know the
    monitoring staff used other program services more often - they
    called the Hotline to resolve difficult questions and they attended
    more trainings.

-   The progress of code compliance can best be monitored if data
    collection begins very soon after the code takes effect. Monitoring
    did not begin until the Energy Code was in effect for 1 year. The
    ramp up period was undocumented, a missed opportunity that may have
    provided insights about the code acceptance and learning process.
    The 1991 Washington State Energy Code overlapped the enforcement
    timetable of the Northwest Energy Code. The two codes were very
    similar, and many Northwest Energy Code jurisdictions participated
    in the Washington Code Program. Since the Washington Monitoring
    Program did not begin until July 1992, it was not possible to
    thoroughly evaluate the Northwest Energy Code impact.

-   Building Departments and builders will sometimes submit to a
    monitoring visit, even if not required to do so. Initially, the
    Program relied on the contract with the jurisdictions to gain access
    to sites, but eventually some non-participating jurisdictions (or
    builders) welcomed monitoring. Code monitoring was effectively
    marketed by offering demonstrations, training, field guides, forms,
    software, and product lists delivered directly to the person who
    needed it. The offer of compliance software training was the most
    effective marketing tool in obtaining non-Program monitoring sites.

# Conclusion

The Washington State Energy Code Monitoring Program was an effective
method to determine relative levels of code compliance. It was also a
useful vehicle in disseminating technical information to builders, code
officials, code trainers, and technical assistance providers. The
monitoring process had a positive and direct effect on overall
compliance. The Monitoring Program showed that code compliance improved
steadily during the four year period of data collection.

The general methodology of data collection and technical assistance used
for the Monitoring Program can be utilized by other entities, if
increased code compliance is the desired result.

# Bibliography

Schwartz, Howard, Richard Byers, and Alan Mountjoy Venning. [Getting to
Code: Costs and Benefits of Developing and Implementing Washington
State's Residential Energy Code, 1983-2003]{.underline}**.** Washington
State Energy Office, July 1993.

Warwick, W.M., A.D. Lee, L.J. Sandahl, D.L. Durfee, and E.E. Richman.
[New Residential Construction Compliance: Evaluation of the Washington
State Energy Code Program.]{.underline} Pacific Northwest Laboratory,
for the US Department of Energy, September 1993.

[Highlights of the 1991 Washington State Energy Code.]{.underline}
Washington State Energy Office, 1991.

P. Fairchild. [Looking Toward a Sustainable Energy Code Enforcement
Future; 1991 Residential Energy Code Program.]{.underline} April 1991.

[A Record of Decision for the Environmental Impact Statement on Energy
Efficient Homes]{.underline}. Bonneville Power Administration, 1989.

Olson, J. R., L. Palmiter, B. Davis, M. Geffon, and T. Bond. [Field
Measurements of the Heating Efficiency of Electric Forced-air systems in
24 Homes, RCDP Cycle III Heating System Investigations.]{.underline}
Ecotope, Inc. for the Washington State Energy Office, October 1993.

[Quality Assurance Plan.]{.underline} Washington State Energy Office,
March 1991.

# Appendix - Monitoring Checklist![](media/image18.wmf){width="8.613194444444444in" height="6.416666666666667in"}

[^1]: ^\*^ The Energy Code defines residential buildings as "buildings
    and structures that provide facilities or shelter for residential
    occupancies."

    The Energy Code defines non-residential buildings as "buildings and
    structures or portions thereof that provide facilities or shelter
    for public assembly, educational, business, mercantile,
    institutional, storage, factory and industrial occupancies."