In 1990 my family took a road trip from our hometown in rural Washington down the west coast to Disneyland. The road trip was fantastic, stopping along the way to see beautiful redwoods and rugged coastlines – that is until we drove into Los Angeles. There we were, sitting in bumper-to-bumper traffic on the largest freeway in the largest city I have ever seen in my short and sheltered life. In every direction, all I could see was the freeway and a few buildings fading into a thick layer of brown smog. Our AC was broken and our windows were down, letting in an acrid smell that burned my nose and throat. My excitement for Disneyland was immediately overpowered with disgust.
Thankfully, in the years since then, the EPA Clean Air Act has given jurisdictions the authority to steadily reduce air pollution emissions and the Los Angeles skies are now much bluer. The South Coast Air Quality Management District (SCAQMD) is one agency that has continued to tighten emissions standards and has very recently taken the bold step to curtail certain emissions to ZERO over the coming decade. This is great news for human and planetary health, but will also have wide ranging impacts for millions of building owners needing to replace aging gas-fired equipment. In the following outline we hope to share more information on exactly what the requirements are, what it means for building owners, and how we at Buro Happold are helping our clients navigate the shifting regulatory landscape.
What changed:
On June 7th, 2024, the SCAQMD amended Rule 1146.2 outlining phased requirements for zero NOx and CO (nitrogen oxide and carbon monoxide) boilers and water heaters starting as soon as 2026 for some new construction projects, and 2029 for some existing buildings. While there are exceptions and extensions for certain situations, the intent of the rule is to drive rapid and wide-spread adoption of zero-emission heating technologies (i.e. heat pumps). The application and phasing schedule is outlined in the table below:
It is important to note that the AQMDs are not the only agencies driving electrification. California’s energy code (Title 24) already requires heat pumps for smaller systems and those requirements are likely to expand to larger systems in the coming years. Furthermore, multiple California municipalities are in the process of developing Building Performance Standards that will reduce the allowed energy consumption and/or emissions allowed from existing buildings, further encouraging electrification.
What it means:
The zero emissions limit applies to newly installed boilers, but also requires old equipment to be replaced at the end of its life (between 15 to 25 years) with zero emissions options replacing the boiler or water heater starting in 2029. This latter requirement essentially triggers electrification of all assets starting as early as 2029 upon asset replacement. While the hope is that technology advancements will reduce the cost and complexity of electrification, the industry is still playing catch-up to develop cost-effective technologies that can be implemented at this scale. In the interim, building owners will be best served by investing in electrification-ready strategies: improving energy performance and reducing peak loads to reduce costs associated with electrification.
What we do:
Electrifying certain building types can be challenging, often triggering significant electrical, structural and hydronic upgrades. To prepare, it’s often important to conduct energy audits and reduce peak loads. In our work on the Empire State Building, and with Campus and Real Estate clients across California, we’ve learned tried-and-true strategies that meet these policies, while reducing the carbon footprint and improving reliability.
We guide our clients through the AQMD requirements, perform energy audits, develop electrification strategies, and provide scenario planning that schedules the best timing to replace existing assets to control capital costs. In addition to regulatory compliance, we help organizations unlock additional benefits that can come with decarbonization measures, like lower operating costs, improving thermal comfort and indoor air quality, EV charging, and leveraging green financing and tax incentives to build a strong business case.
Looking ahead:
While these requirements might feel abrupt for an industry that traditionally embraces change very cautiously, the reality remains that we must act swiftly to curtail our emissions and prevent the most severe climate change outcomes. These mandates will inspire fresh incentives and innovation, propelling the rapid adoption of electrified buildings.
(posted 10/3/24)
Authors:
- Lead: Sarah Moore, Buro Happold
- Contributors: Julian Parsley, Kathleen Hetrick, Buro Happold
About the Lead Author:
Sarah Moore is a principal at Buro Happold and leads the MEP engineering team based out of Seattle. In Sarah’s 20 years of experience, she’s served as energy modeler, code and sustainability consultant, MEP design engineer, and multi-discipline project manager. She’s had the opportunity to work on a wide range of project types, from midtown Manhattan office towers, to a new Ivy League Performing Arts Center, to flagship retail locations for a global retailer, to phased retrofits of hospital and lab systems requiring continuous operation through construction
Sarah’s most recent experience focuses on existing building optimization, especially decarbonization and electrification, real estate repositioning, COVID response, and health and wellness improvements for occupants and communities. She seeks intelligent win-win solutions that serve the needs of each customer while leading toward a sustainable, healthy, and equitable future.
Related Content:
To learn about USGBC-CA’s Building Performance Peer Learning Collaborative, please click here.
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