The Department of Energy (DOE) has requested input on how it can improve its methodology for assessing cost effectiveness of changes to residential building energy codes. (See Federal Register/Vol. 76, No. 177, Page 56413/Tuesday, September 13, 2011/Notices).
For many, the first question this brings to mind is why DOE is looking at this issue, since building codes are the province of state and local governments. The short answer is that the Energy Conservation and Production Act (ECPA) makes it DOE’s business.
Under Section 307 of ECPA, DOE is required to support the upgrade of voluntary building energy codes for new buildings, including “assistance in determining the cost-effectiveness and the technical feasibility of the energy efficiency measures included in such standards and codes.” It is required to periodically review energy codes and (1) recommend amendments, (2) seek adoption of “all technologically feasible and economically justified energy efficiency measures,” and (3) otherwise participate in the code revision process.
For residential buildings this means primarily the International Energy Conservation Code (IECC), which is a model code adopted by the International Code Council (ICC) that forms the basis for the majority of energy codes adopted by the states. Consequently, changes to the IECC advocated by DOE based on its view that they constitute cost effective energy efficiency measures can have a significant impact on the ultimate building energy codes adopted by state and local governments.
This potential impact is magnified because after the ICC adopts a new revision of the IECC (which it does on a three year cycle), Section 304 of ECPA requires DOE to determine whether the revision would improve energy efficiency in residential buildings. If DOE determines that it does, then each state is required to certify that it has reviewed the energy efficiency of its own building code and determine whether it is appropriate to revise its code to meet or exceed the revised IECC.
This is a long way of saying that this request for information matters. For those who object that revisions such as the 2009 IECC are too expensive, it may be that the most effective strategy is to move the battlefront from objecting to state adoption of IECC to seeking to influence DOE’s analysis of the cost effectiveness of measures in the first place before they are even proposed for the IECC.
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