About

With extensive improvements including a solid 5-10% boost in residential and commercial efficiency over the 2018 IECC, on top of the 30% gains in efficiency since the 2006 IECC, and voluntary Zero Energy appendices for jurisdictions seeking further improvements, the 2021 IECC is the latest and best version of the model energy code. As a result, the provisions of the 2021 IECC should be the starting point and the minimum baseline for any analysis of future proposed changes.

In the past, the level of improvement to the IECC in each code cycle has fluctuated enormously, with most of the gains coming during the 2009, 2012, and 2021 cycles. A steady and deliberate path of improvement is in the public interest. Efficiency improvements are needed in each new edition without any rollbacks to meet the energy efficiency and emissions reduction targets of cities and states that adopt the IECC.

We oppose residential and commercial code proposals that weaken the energy efficiency of a building or system, impair the effectiveness of code provisions, or undo improvements included in the 2021 IECC and IRC or previous code editions.

We recognize the importance of efficiency, grid interactivity, renewable energy, and electrification in the achievement of carbon emissions reduction. While we support the adoption of all reasonable energy code improvements, we are especially supportive of measures that improve durability, long-term performance and longevity while maintaining occupant comfort, simplicity, and ease of enforcement. Because buildings can last 100 years, retrofits are far more costly than the same improvements at initial construction, and opportunities to incorporate measures that achieve long-term energy savings and emissions reductions may not come around again for a long time, it is particularly important that the IECC optimize efficiency and systems infrastructure improvements at construction. A measure’s cost-effectiveness must compare incremental outlays with the value of energy, carbon, and other savings over the life of the building. In practical terms, this means that either Life-Cycle Cost or Mortgage Cash Flow analyses should be the basis for determining cost-effectiveness, applying a minimum building life of at least 30 years and calculating “time to positive cash flow.” The Department of Energy’s cost effectiveness methodologies are good examples of how these analyses may be conducted. Simple payback or other limited analytical methods should not be considered valid evaluation tools. Finally, cost-effectiveness should not be the sole consideration; proposals should also be weighed on their simplicity, ease of enforcement, and other owner/occupant impacts like improved occupant comfort and health and resale value, as well as public benefits such as reduced peak energy demand, deferred need for new power plants, and energy and environmental policy benefits.

A single, simplified prescriptive compliance path is crucial to the effectiveness of the IECC and establishes a clear target for all stakeholders, improves efficiency, reduces design and construction costs, eases both compliance and enforcement, and leads to market transformation. While we generally support multiple non-prescriptive reasonable compliance options (such as a UA trade-off, performance path and ERI compliance path), minimum mandatory measures and trade-off backstops are essential in order to ensure that critical measures with long lives (such as envelope efficiency, air leakage, etc.) are not traded off for short-term measures and that the building has minimum “whole building” efficiency. In addition, ensuring that complementary compliance options, such as a performance path, are at least as efficient as the prescriptive path provides code users with flexibility without sacrificing owner/occupant benefits. EECC also supports offering jurisdictions an array of options to achieve additional energy efficiency, carbon reduction, and other benefits.

We strongly oppose the adoption of prescriptive “trade-offs” against current prescriptive path requirements. By definition, in the best case, trade-offs result in no energy efficiency gains, yet serve to complicate or undercut code enforcement and compliance; however such trade-offs often result in reduced efficiency. We can support reasonable “trade-ups,” including the Additional Efficiency Options in both the residential and commercial chapters of the IECC, which boost energy efficiency by offering a choice among several options that may be difficult to adopt at this point as stand-alone prescriptive requirements.

We oppose proposals that would permit code users to use more efficient mechanical equipment (HVAC and water heating), lighting, appliances, or on-site power production, such as solar PV, as trade-offs against other base code efficiency requirements under the residential performance compliance path. Federal law prohibits adopting jurisdictions from setting requirements for certain residential mechanical equipment higher than the federal minimum efficiency for these products. The minimum standards set by the federal government are often well below standard practice. As a result, these trade-offs, if allowed, would constitute a major code compliance loophole. Moreover, such trade-offs do not consider the long-term importance of minimum building envelope performance and the typically much shorter useful life of equipment. (Such trade-offs were eliminated from the IECC in 2009 and they have been rejected in every code cycle since then.) For similar reasons, we oppose performance path trade-offs for lighting and on-site generation (renewable or otherwise), which were also rejected in previous code update cycles. Those who wish to take credit for improved equipment and other such measures in residential buildings may use the ERI approach, which accounts for the free-ridership problem through a more stringent ERI target value and crucial minimum envelope backstop requirements.

We support the IECC as a stand-alone comprehensive energy code for all buildings, including all commercial buildings. Future IECC commercial building requirements should be as efficient as – or exceed where possible — the latest version of ASHRAE Standard 90.1. In cases where existing or proposed IECC requirements are more efficient or otherwise better than provisions in Standard 90.1, or are likely to result in increased compliance, ease of enforcement and market transformation, we support these requirements in the IECC and encourage their adoption by ASHRAE. In our view, the symbiotic relationship between the two codes makes both codes better and more efficient.

We oppose industry- or product-specific special exemptions or provisions. We believe that all types of buildings and all material types should generally be required to achieve the same level of energy efficiency.

We support reasonable independent product, system and building testing, certification and labelling requirements to ensure fair competition in the marketplace, consumer protection, and improved code compliance and enforcement.

We support improvements to the IECC and other International Codes to ensure that additions, renovations, replacements and repairs achieve reasonable energy efficiency.

We support the adoption of all reasonable energy code proposals that boost the energy efficiency of residential and commercial building construction and renovation and are consistent with our other principles, regardless of author. If proposals by other proponents are better than EECC proposals, we will support the best proposal.