Measure Overview
This measure would add prescriptive requirements to Title 24 Part 6 to ensure that unitary Heat Pump / Electric Resistance (HP/ER) hybrid water heaters are specified and installed in a way that minimizes electric resistance use. The proposed measure would apply to new construction, alterations, and additions in Nonresidential (NR) buildings.
The measure would require unitary HP/ER HPWHs to be installed according to the manufacturer’s design and installation guidelines, set a minimum compressor cutoff temperature for both heat pump only and hybrid (heat pump and electric resistance) operating modes, and require that the HP/ER HPWH can operate in heat pump-only mode under the heating design day 0.6% dry bulb temperature.
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The Statewide Utility Codes and Standards Team is conducting a survey to inform nonresidential code change proposals for the 2028 California Building Efficiency Standards (Title 24, Part 6).
In appreciation, we will send you a $20 Tango gift card or donate this amount to your local United Way upon completion of the survey.
Take the SurveyScope of Proposed Code Change
| Building Type(s) | Construction Type(s) | Type of Change | Updates to Compliance Software | Third Party Verification |
| Nonresidential | New construction, additions, alterations | Prescriptive | Update existing feature, add new feature | No changes to third party verification |
Justification for Proposed Change
In California approximately 22 trillion BTUs are used for water heating in commercial buildings (CBECS microdata 2018). The majority of the SHW energy use (79%) is from natural gas with just 19% from electricity (CBECS microdata 2018). Utility incentive programs for HP/ER HPWHs have attempted to capture a portion of this opportunity, but configuration and operation issues are demonstrating lower than expected performance (in terms of coefficient of performance, COP) when HP/ER HPWH are installed as the heat source for central DHW systems.
One key component contributing to reduced COP is the activation of the ER heating elements. ER heating can be triggered for several reasons including but not limited to:
- HPWH supply air temperature is too low for compressor operation as a result of
- Insufficient ventilation in installation location
- Cool winter temperatures
- HPWH operating mode: some models have 10°F lower compressor cut out temperature in efficiency (HP only) mode versus Hybrid mode setting
- HPWH control algorithm is attempting to avoid a perceived potential hot water runout event from:
- The use of master mixing valves or pump controls that improve tank stratification with more cold water in the lower part of the tank but trigger more heating activations
- Elevated HPWH temperature setpoints that may trigger more heating activations from the algorithm identifying a larger temperature difference from the top to bottom of the tank which can be related to draws or return temperatures from a recirculation loop
- HPWH set point temperature is higher than the HPWH can achieve using HP only
Ensuring that installed Hybrid HPWHs comply with the manufacturer’s installation guidelines will minimize the chance that HPWHs will overcool the space in which they are installed and reduce excessive ER heating. Enforcing a specific HPWH compressor cutoff temperature will improve efficiency and help designers understand the HPWH operation characteristics to ensure that it can deliver hot water in all conditions.
By accomplishing the above goals, installations of central systems with unitary hybrid HPWHs will be more successful and demonstrate the capability for electrification without the high energy costs associated with ER heating.
Relevant Documents
Round One Utility-Sponsored Stakeholder Meeting Materials
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Give Us Your Feedback
The Statewide CASE Team values input from all stakeholders engaged in the Title 24, Part 6 code change process. We encourage the open exchange of code change comments and concerns.