Time to Vote! Building Code Officials Hold the Power

Important note: the Online Governmental Consensus Voting period has been extended until 11:59pm Pacific time on Sunday, November 27. We encourage all eligible members to go vote!

As the country prepares to vote for the next president, state and local building code officials are preparing for an additional round of voting: the decision of what the nation’s building energy codes will look like beginning in 2018. NRDC is confident these local officials will keep the code moving in the right direction—toward more energy efficiency in buildings and huge energy bill savings while creating a more sustainable future for all of us.

Americans spend more than $200 billion each year on their energy bills but a recent Department of Energy report found that a modest 4 percent to 5 percent increase in the stringency of the building energy code could cumulatively save consumers $126 billion on their energy bills from 2010 to 2040. Those are real savings for building owners and occupants and the reduced energy use from such improvements as more efficient windows or thicker insulation also helps avoid the pollution from fossil fuel-fired electricity generation that fuels climate change.

The upcoming building codes vote is the final step in the development of the 2018 International Energy Conservation Code (IECC), which is the model energy code recognized by the Department of Energy (DOE) and cited in federal law. It is updated every three years through a stakeholder process involving code officials, builders, efficiency advocates, and other interested parties. It's then up to state and local jurisdictions to adopt and enforce the codes. The IECC is used by more than 40 states.

The online ballot is open from November 8 through November 21 and code officials can vote here: https://cdpaccess.com/login (a guide to how to use CDP Access can be found here: http://www.iccsafe.org/cdpaccess/).

As in all elections, every vote really does count! In the past, decisions regarding the codes that will govern U.S. residential and commercial buildings have been made on proposals by very slim margins. NRDC encourages code officials to get out the vote all the way to November 27 (note that the voting period has been extended!). In many jurisdictions, multiple code officials have voting privileges; typically the larger the jurisdiction, the greater the number of officials eligible to cast votes.

Background

There are hundreds of proposals on the ballot for consideration in the 2018 energy code. A number of them strengthen the code , but quite a few weaken the code. Unfortunately, the building energy code is under attack at precisely the time when it is crucial to ensure that code is stronger than ever to increase the resilience of communities against the impacts of climate change .

For a code official who only has time to vote on a handful of proposals, NRDC’s recommendations are outlined below. For those interested in voting on a wider variety of proposals, we recommend following the voting guide put together by the Energy Efficient Codes Coalition (EECC). NRDC’s views are widely consistent with the EECC recommendations, with the exception of RE-166, which we strongly urge code officials to approve as modified by public comment 1 (AMPC 1).

Residential Proposals

RE19-16 – Improved Windows: APPROVE AS SUBMITTED (AS)

• This proposal requires more efficient windows in all paths of the code.
• The efficiency levels specified are already widely available.
• Code officials voted to recommend approval during the public comment hearings.

RE87-16 – Increased Air Leakage: DISAPPROVE (D)

• This proposal reduces the efficiency of a home by allowing for more air leakage in climate zones 3-8 (all of the country except for Florida and the southernmost parts of the Gulf states).
• A leakier home means more heated or cooled air escapes to outside of the building envelope. This is a clear rollback of the code.
• Code officials voted to recommend disapproval during the public comment hearings.

RE113-16 – Prescriptive Water Heater Efficiency: APPROVE AS SUBMITTED (AS)

• For homes in climate zones 1-5 (warmer and moderate climates), complying with the code using the prescriptive path, this proposal requires the use of one of six types of water heaters.
• As the residential thermal envelope (meaning all the parts of a home that separate the conditioned space from the outdoors or unconditioned space: insulation, windows, exterior walls, roof, etc.) has gotten better in recent code cycles, water heating has become a proportionally higher end-use.
• This proposal helps ensure that homeowners aren’t wasting energy on heating water, and does so in a way where the options are cost-effective for the homeowner.

RE114-16 – Efficient Lavatory Faucets: APPROVE AS SUBMITTED (AS)

• This proposal sets the maximum flow rate of residential lavatory faucets at 1.5 gallons per minute, which is the same level specified by the EPA Water Sense program in 2007.
• Thousands of faucet models in all styles and finishes meet this specification, and at no added cost for their energy and water savings.

RE134-16 – Equipment Trade-Offs in the Performance Path: DISAPPROVE (D)

• Code officials correctly rejected this proposal in 2009, 2012, and 2015.
• Builders would be able to take credit in the performance path for any efficiency gains between the federal minimum standard HVAC equipment and the type of equipment they install, and instead install less insulation or less-efficient windows. 
• More than 90 percent of equipment installed is already more efficient than the minimum standard. This proposal would create a huge free-ridership loophole and result in a less-efficient home.

RE135-16 – Stronger Envelope Requirements for the Performance Path: APPROVE AS SUBMITTED (AS)

• This proposal applies the same minimum thermal envelope requirements to the performance path as is required in the Energy Rating Index (ERI) path.
• Applying the same tighter, more efficient building envelope requirement to the performance path would make homes more efficient.

RE166-16 – Reference to ANSI/ICC/Resnet 301 Standard in the ERI Path: APPROVE AS MODIFIED BY PUBLIC COMMENT 1 (AMPC1)

• This proposal adds certainty to the ERI path of the code by clarifying that the calculation of the ERI score shall be done in accordance with the ANSI/ICC/Resnet 301 standard. This is already the industry standard, so while very little functional change will occur, the proposal ensures that all customers are receiving a high-quality product if their home complies with the ERI path.
• However, the ANSI/ICC/Resnet 301 standard allows for an unlimited amount of onsite energy generation. RE166-16 must be passed in conjunction with RE173-16, which provides a strong efficiency backstop for homes with onsite power generation.

RE173-16 – Modified ERI numbers and On-Site Generation Backstop: APPROVE AS MODIFIED BY PUBLIC COMMENT 1 (AMPC1)

• Public Comment 1 provides a crucial backstop for homes with onsite generation, like solar panels. It requires that homes that use renewable energy to comply with the ERI path requirements meet the strong 2015 building thermal envelope backstop.  This fixes a crucial loophole that puts cost-effective efficiency at risk.
• Public Comment 1 was a broadly supported compromise proposal supported by NRDC, the builder community, energy efficiency and building code advocates, the insulation industry, and voting members at the public comment hearing.
• NRDC does not support the proposal without  the public comment

RE179-16 – 5 percent Improvement of the Residential Code: APPROVE AS SUBMITTED (AS)

• Improves the overall efficiency of the IECC residential provisions by about 5 percent.
• Does so by using a flexible, points-based system that leaves the compliance choices entirely up to builders.

RE191-16 – Water Heater Proximity to Fixture Outlets: APPROVE AS SUBMITTED (AS)

• This proposal promotes compact design of domestic hot water distribution systems, to reduce the waste of energy and water from purging cooled-down water while waiting for hot water at a shower or faucet.
• It sets a "low bar" prescriptive requirement for water heater proximity that most production home plans will easily meet and offers a performance path credit in section R405 for projects with closer proximity than the prescriptive values.
• Compliance is easily confirmed at plan check; no measurements or calculations are done at the job site.

Commercial Proposals

CE43-16 – 5 percent Improvement of the Commercial Code: APPROVE AS SUBMITTED

• Improves the overall efficiency of the IECC commercial provisions by about 5 percent

CE175-16 Parts 1 and 2 – Efficient Showerheads: APPROVE AS SUBMITTED (AS)

• This two-part proposal sets the maximum flow rate of showerheads in both the commercial and residential sections of the code at 2.0 gallons per minute, which is the level specified by the EPA Water Sense program since 2010.
• Thousands of showerheads in all styles and finishes meet this specification, and at no added cost for their energy and water savings.
• 2.0 gpm is ample for a vigorous shower, and models with pressure-compensating flow are available to ensure good performance in buildings with low water pressure.

CE247-16 – Efficient Lavatory Faucets: APPROVE AS SUBMITTED (AS)

• This proposal sets the maximum flow rate of residential lavatory faucets installed in apartment buildings at 1.5 gallons per minute, which is the level specified by the EPA Water Sense program since 2007.
• Thousands of faucet models in all styles and finishes meet this specification, and at no added cost for their energy and water savings.

Administrative Proposals

ADM 42-16, Parts 1 and 2: DISAPPROVE (D)

• Weakens the code by changing the intention from “effective” energy use to “net energy use.”
• The proposal is poorly crafted, lacks definitions for the term “net energy,” and would put the intent of the code to conserve energy in jeopardy.
• Code officials voted to recommend disapproval during the public comment hearings.

ADM45-16, Parts 1 and 2: DISAPPROVE (D)

• This proposal removes the phrase “over the useful life of the building” from the administrative section.
• The removed language is crucial to ensure that the code remains a tool for saving energy and protecting and serving the needs of homeowners over the long term.
• Code officials voted to recommend disapproval during the public comment hearings.

Code officials have a civic duty that goes beyond voting for politicians: they get to control the energy future of the new buildings in our country. We urge code officials to use this power to advance energy efficiency and make the future brighter for all of us.