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Energy Retrofits – Utility Approval is Only a Starting Point
Utility application approval for your project is a good thing – but it is not everything!
By Murray Johnson | Other articles by Murray Johnson
Although it sounds strange, condominium boards and managers must look beyond energy reduction when we look at energy retrofits. If the goal were ultimate energy reductions, we'd only need to mimic our prehistoric ancestors and their cave technology - turn all the lights off, turn off the heat and hot water and presto! Huge Savings!
Clearly, we must balance ultimate energy reduction with other factors that are equally important in condominiums. Specifically, we should aim to improve the quality of life at our building, minimize operating expenses and add long-term value without increasing liability to the corporation. Keeping this in mind means that energy projects must consider more than simply reducing kilowatt hours, cubic meters of gas or litres of water that are used.
Unfortunately, it is a fairly common occurrence that lighting retrofits do not even meet the municipal light level codes. It does not take much imagination to see that this could easily develop into a law suit against the condominium for approving a lighting project that did not meet code. Would insurance even cover a condominium that approved a retrofit to below code requirements should some unforeseen tragedy occur in the low light areas? The vast majority of lighting proposals are quick to point out energy savings and maintenance savings, but are silent on light levels. Sadly, there are very few companies in the GTA that measure light levels both pre-project and post-project to ensure compliance, unless it is made a requirement. When questioned, many providers feel it is sufficient to say their proposals "increase light levels vs current" without referencing code requirements, and ignoring that the current state of the lighting might be poor given the lamps have not been changed in quite some time. Many lighting sales companies don't even follow the code requirements for taking light level readings.
Perhaps nowhere is selling energy retrofits by omission more obvious than with the use of motion, or occupancy sensors in condominiums. Proposals that utilize this technology never state that the sensors they plan to employ are not compliant with municipal property standards. Compliant sensors are much more expensive, and thus often not proposed for fear the contractor will lose the sale on the basis of price. These companies perhaps prefer you do not know any of the details, or worse, they do not know the codes themselves.
For clarity, these unfortunate instances occur in more than just the lighting industry. The pressure for condominiums to reduce costs and the rapid increase in emerging lighting companies make lighting a good example to use as they occur more frequently these days. The issues go deeper than just code compliance.
For example, it is curious to see how eager a board of directors is willing to accept a five year warranty from a company that has not been in business for two years – will that company be there to honour the warranty should something fail? The warranty documents themselves unfortunately mirror the variation in the quality of energy retrofit products. When it comes to lighting, new technologies do not fail the same way a regular light bulb does - this can lead to creative warranty language that defines "lamp failure" to the huge benefit of the contractor. There are also issues when it comes to the installation – are the proper permits being applied for and proper procedures being followed? For example, it is critical that a condominium understand that retrofitting an existing fixture voids the CSA certification of the existing fixture. We must ensure the contractor is following the proper Electrical Safety Authority procedures so that the retrofit does not void the condominium's insurance policy. With many projects resulting in lower light levels than code, improper use of motion sensors, poor installation practices and vague warranties, it raises the question of the role of the electric utility companies, or LDCs (Local Distribution Companies). Many directors and managers believe that an approved incentive application from an LDC protects them from the above problems. This simply is not true. LDCs do not condone such behaviour of course, but it is not their role to verify all matters relating to an energy project. LDCs play a different role – they administer the incentive programs following the rules laid out by the regulators. For example, an incentive application over $10,000 requires an LDC to coordinate a site visit to confirm the existing conditions. This process provides some assurance that the condominium will receive the electrical reductions proposed by the contractor. LDCs also check for evidence of paid invoices and proper equipment disposal – these are critical to ensure our tax dollars are spent with proper due diligence. No such requirements are place for projects under $10,000.
LDCs are also required to deliver a specific amount of electrical savings. These savings are important as the Province depends on these savings as an input into their long-term electricity plans. LDCs deliver these savings by promoting incentive programs and providing resources to the condominium industry utilizing such programs. Their goal is simply to reduce consumption and they promote that mindset no matter what.
So, while the role of an LDC is important, directors and managers need to realize that an approved incentive application from an LDC should not be perceived as an endorsement to proceed, or a guarantee of a "reasonable" project. Directors and managers must perform their own due diligence. Consider asking the following questions, or requiring the following to be included when considering a lighting retrofit project:
1. How long have you been in business and what contractual assumption guarantees are in place to ensure that the warranties will be honored if the installer is no longer around?
2. What products are being used? Is a reputable company behind the product in case of issues? Is there an option to use name-brand components where they will hold the warranty?
3. What is the guarantee the motion sensors being used meet the local municipal code requirement to see through smoke?
4. Are you doing mock-ups to show pre and post light levels and consumption patterns? Have the installer show how their readings meet the placement of light meters as noted in the codes.
5. Are the assembled products UL (or similar authority) certified as a completed component?
6. Is the installer a certified and licensed electrical contractor?
7. Have all inspection permits and reports been supplied? Be careful when retrofitting existing fixtures.
8. Who is the constructor for the project? Who is submitting the Ministry of Labour Notice of Project?
9. Do all trades have full Occupational Health and Safety Act (OHSA) training and certificates? Do you have proof?
10. Are correct disposal certificates being provided?
11. Did you receive references from sites that have now passed their warranty period?
12. If the lighting pattern is being changed, is the new design engineered and approved to meet code?
A critical question to ask is: "Considering all technologies available today (high output florescent, LED, LED tubes, induction, etc.) is the proposal the best option compared to the other technologies?" With all three parties to energy reduction projects at odds with each other, it can be hard to determine what to do. An LDC says "go for it, it's reducing consumption", the sales guy is telling you his is "the best option" and the condominium must consider operating costs, code, insurance and the many other aspects discussed here. Some solutions seem to be very trendy or sexy, but nothing beats due diligence.