Monday, February 23, 2015

BOMA California Energy Update - AB 1103 Review, Proposed Changes to Title 24, EV Charging Stations

AB 1103 Review

BOMA California representatives have recently participated in a workshop at the California Energy Commission (CEC) where their staff is seeking input regarding proposed changes to regulations for the Nonresidential Building Energy Use Disclosure Program - also known as the AB 1103 Program.

Energy Commissioner Andrew McAllister and Commissioner Karen Douglas are leading an effort to review the regulations and make sure they implement the underlying legislation in the most efficacious way possible.

Throughout the last few years BOMA members have worked closely with the Energy Commission to help them better understand the policy issues related to the implementation of the AB 1103 regs on owners and managers.

Click here to review language. Many of the suggested changes our industry has provided in the past are now incorporated into the suggested regulations, including a new definition for “building operator,” clarification of when the information is to be provided, and clarification that tenant information is to be provided to owners/managers by utilities without the need for tenant authorization.

Since many of you have now had direct experience with implementing AB 1103 your input is that much more valuable.

Proposed Changes To Title 24

The official proposed changes by the California Energy Commission to Title 24, Part 6 (CA Energy Code) was released earlier this week. BOMA California is currently trying to analyze the proposal and prepare comments on behalf of industry.

The Notices of Proposed Action for the 2016 revisions to the Title 24 Part 6 Building Energy Efficiency Standards, and separately for the voluntary provisions in Title 24 Part 11, can be found here.

If you have experts at your company that can review the proposed regulations and provide feedback that would be helpful.  Send all comments to

Final proposed codes are scheduled for adoption at the CECs May 2015 Business Meeting.

Electric Vehicle Charging Stations

Over the past six months, there has been a growing level of controversy focusing on whether electric vehicle (EV) parking spaces should be accessible to those with disabilities. In response, the Building Standards Commission directed the Division of the State Architect (DSA) to convene a group of stakeholders to identify key issues and make recommendations that would be used by DSA in developing amendments to California’s disabled accessibility building standards. To date, DSA has conducted six workshops with the seventh planned for February 11th.

BOMA has been represented at each of these gatherings and the Governor’s Office is now actively engaged with this group as well.

Some advocates would like to see all EV-charging stations meet the dimensional specifications required for van-accessible parking spaces. This change would require parking spaces to be roughly 17-20 feet in width instead of the standard 8-9 feet, effectively taking out at least two parking spaces for each EV-charging station installed.

On behalf of our members, BOMA is supporting the currently held notion that EV-charging is a service and should be treated no differently than other services which require the standard 4% accessibility application rule. Requiring all stations meet the suggested requirements by the advocates for the disabled community would unnecessary complicate compliance and could ultimately cause less EV-charging installations to occur.

EV-Ready Building Standards Set to Take Effect on July 1, 2015

In response to an Executive Order issued by the Governor in late-2012, the California Building Standards Commission (CBSC) and the Department of Housing & Community Development (HCD) have adopted regulations to require the installation of Electric Vehicle (EV) ready infrastructure. As opposed to installing fully operational (and costly) charging stations for electric vehicles, these EV-ready building standards would be limited to items which would facilitate the later installation of the charging stations at a significantly reduced cost.

For example, new commercial buildings having parking lots containing more than 49 spaces will be required to have an electrical panel with enough empty plug slots to allow for the later installation of EV charging equipment. In addition, there will also need to be one-inch wide conduit (piping) provided for the later installation of the wiring connecting the electrical panel with a point in close proximity to the designated EV service space.

Environmental organizations and the Air Resource Board (ARB) had argued for the installation of fully functioning EV charging facilities, however, after hearing concerns expressed by us, the CBSC has chosen to move forward with only “EV-ready” regulations. Doing this also helps avoid issues related to disabled accessibility that will take much longer to resolve.

For commercial building parking facilities, the required number of EV-Ready parking spaces shall be 1 EV-ready space for every 50 parking spaces.

These new EV-Ready building standards will apply to projects for which the permit application is submitted to the local building department on or after July 1, 2015.

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