What is the Energy-Efficient Codes Coalition?
The Energy-Efficient Codes Coalition (EECC) brings together an ever-growing group of building sector advocates and supporters who are committed to improving the energy efficiency of the International Energy Conservation Code (IECC) and setting America’s model building energy code on a glide-path to net-zero energy construction. EECC’s supporters include a diversity of businesses, trade associations, energy efficiency organizations, environmental groups, and consumer advocates that understand how homeowners, tenants, businesses, and state and local governments all benefit from steady increases in energy efficiency in the built environment. When engaging in the 2021 IECC development process, EECC will rely on 12 principles when setting priorities, conducting analyses, evaluating the energy efficiency of proposals, and developing vote recommendations. EECC was originally established in 2007 by the Alliance to Save Energy.
What is the Energy-Efficient Codes Coalition?
The Energy-Efficient Codes Coalition is a project of the Alliance to Save Energy, and is an ever-growing coalition of building energy-efficiency supporters including diverse businesses, nonprofit organizations and government entities that share in the belief that homeowners, business owners, builders, local governments, and our overall economy all benefit from energy efficiency, and that the IECC should serve as a glide path to Net Zero energy construction.
Top energy-efficiency experts and advocates formed the Energy-Efficient Codes Coalition in mid-2007 with the goal of achieving a 30 percent boost in energy efficiency over the 2006 International Energy Conservation Code (IECC). We achieved that goal for homes and commercial buildings via the 2009 and 2012 IECC, but have stalled on achieving significant gains since then.
EECC believes it is critically important that the 2021 IECC be at least 10% more efficient than the 2018 IECC to make significant gains toward setting America on a glide path to home and commercial building affordability, stable energy costs, energy independence and reduced greenhouse gas emissions. With additional votes this code cycle, we can propel America toward the direction of Net Zero and benefit all citizens.
National Association of State Energy Officials
Urban Sustainability Directors Network
Broad-Based Energy Efficiency Groups
The Alliance to Save Energy
American Council for an Energy Efficient Economy (ACEEE)
United Nations Foundation
Institute for Market Transformation
Regional Energy Alliances
Midwest Energy Efficiency Alliance (MEEA)
Northeast Energy Efficiency Partnerships (NEEP)
Northwest Energy Codes Group (NEEA)
South-central Partnership for Energy Efficiency as a
Southeast Energy Efficiency Alliance (SEEA)
Southwest Energy Efficiency Project (SWEEP)
American College and University Presidents Climate
Center for Resource Solutions
New Building Institute
Affordable Housing Advocates
Enterprise Community Partners
Global Green USA
Housing Assistance Council
LISC – Local Initiatives Support Corporation
National Housing Institute
National Low Income Housing Coalition
American Institute of Architects
Ed Mazria, Architecture 2030
Consumers Federation of America
Energy Outreach Colorado
American Values Network
Energy Efficient Construction Organizations
New Buildings Institute
Blue Green Alliance
Business and Insurance
American Chemistry Council
Business Council for Sustainable Energy
Environmental Business Council – New England
Extruded Polystyrene Foam Association (XPSA)
Green Chamber of Commerce
North American Insulation Manufacturers
Northwest Environmental Business Council
Polyisocyanurate Insulation Manufacturers
Structural Insulated Panel Association (SIPA)
Center for Environment, Commerce & Energy
Climate Crisis Coalition
Community Environmental Council
Environmental Law and Policy Center
National Wildlife Federation
Natural Resources Defense Council (NRDC)
American Public Power Association
Edison Electric Institute
National Rural Electric Cooperative Association
EECC’s Guiding Principles
EECC’s Guiding Principles
In drafting EECC proposals and developing our positions on proposals authored by others for the 2021 code cycle, EECC operates under twelve guiding principles:
1. The 2018 IECC Is the appropriate foundation for future improvements to America’s model energy code (the IECC).
With a historic boost of greater than 30% in residential and commercial efficiency over the 2006 IECC, the 2012 IECC exceeded the original goal set by EECC, US DOE and other stakeholders. US DOE called the 2012 IECC “the largest, one-step efficiency increase in the history of the national model energy code.” The 2015 IECC, taken as a whole, retained the 2012’s efficiency gains and made important improvements, particularly its new residential Energy Rating Index (ERI) path, with the potential to produce additional new home efficiency. The 2018 IECC upheld the 2015 residential compliance path requirements and added modest residential efficiency improvements. In addition, while the 2018 IECC increased ERI scores, it also settled a question about on-site generation through a “trade-up,” which only recognizes on-site generation after the 2015 IECC’s prescriptive requirements are met. As for the 2018 IECC commercial provisions, there were limited improvements over the 2015 version and the ASHRAE 90.1 compliance path was upgraded to the most recent version. As a result, the 2018 IECC should be the starting point and the baseline for any analysis of future proposed improvements.
2. For the 2021 IECC and its successors, a Glide Path of reasonable, but steady improvements in energy efficiency in each code cycle should be established.
In the past, the level of improvement to the IECC in a given code cycle has fluctuated enormously, with most of the gains coming during the 2009 and 2012 cycles. The changes made during those cycles have been “digested” and now is the time to chart a course for future significant improvements. A more steady and deliberate path of future improvements should, in addition to energy efficiency gains, advance code simplicity, ease of enforcement, cost-effectiveness and savings, improved occupant comfort and other energy and environmental policy benefits.
3. No backsliding or rollbacks.
We oppose residential and commercial code modifications or proposals that weaken the energy efficiency of a building or system, or overturn gains and improvements included in the 2018 IECC and IRC. We also support recapturing any efficiency losses that resulted from previous code development processes.
4. Simplicity, ease of enforcement, cost-effectiveness, longevity, comfort & energy/environmental benefits are also paramount considerations in evaluating each potential IECC code change.
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. Because buildings can last 100 years, retrofits are far more costly than the same improvements at initial construction, and opportunities to correct mistakes may not come around again for a long time, it is particularly important that the IECC “build them right” up front. Consistent with the tenet that the longer a specific improvement lasts, the more energy savings value it brings, the IECC’s “Statement of Intent” (in sections R101.3 and C101.3) specifically focuses on “the effective use and conservation of energy over the useful life of each building.” Similarly, an efficiency measure’s cost-effectiveness must compare incremental outlays with the value of energy and other cost 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 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 analytical methods that are inconsistent with the IECC’s intent should not be considered valid tools for evaluating the cost-effectiveness of IECC proposals. In addition, other important factors should also be carefully considered in developing and evaluating potential code changes, such as code simplicity, ease of enforcement, and other positive effects such as reduced peak-energy demand, improved occupant comfort, and energy and environmental policy benefits. An important goal of an improved energy code should be to promote the health, safety and/or welfare of building occupants and the public.
5. The IECC should include a reasonable set of compliance options, but they must be at least as efficient as the Prescriptive path. A single simplified Prescriptive compliance path leads to greater compliance, enforcement and market transformation for residential and commercial construction.
A single, simplified prescriptive compliance path with reasonable measures and individual building assembly performance requirements establishes a clear baseline target for all stakeholders, improves efficiency, enhances quality, reduces construction cost, and eases both compliance and enforcement. While we generally support multiple non-prescriptive reasonable compliance options (such as a UA trade-off, performance path and ERI compliance path) to comply with the IECC, minimum mandatory measures 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 house” 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 an array of options to achieve additional energy efficiency above a fixed prescriptive path baseline. We see properly and carefully designed “outcome-based” code provisions only as a possible supplement to, but not a replacement for, code requirements for design and construction that are enforceable prior to a certificate of occupancy.
6. Adopt “Trade-Ups,” not “Trade-Offs.”
We strongly oppose the adoption of prescriptive “trade-offs” against current prescriptive path requirements (by definition, trade-offs result in no energy efficiency gains, yet serve to complicate code enforcement and compliance). We can support reasonable “trade-ups” that boost energy efficiency by offering a choice among reasonably equivalent options (reflecting energy cost savings and other energy efficiency benefits over the useful life of each option) that may be difficult to adopt at this point as stand-alone prescriptive requirements.
7. Reject Residential equipment and related trade-off loopholes.
We oppose proposals that would permit builders to use more efficient mechanical equipment (HVAC and Hot Water) as a trade-off against other base code efficiency requirements under the residential performance compliance path. Federal law prohibits the IECC and adopting jurisdictions from determining and setting prescriptive or baseline requirements for certain residential mechanical equipment. The minimum standards instead are often set by the federal government well below standard practice. As a result, these trade-offs, if allowed, would constitute a major code compliance loophole; the ICC eliminated such trade-offs from the IECC in 2009 and has rejected their reintroduction in every code cycle since then. Moreover, such trade-offs do not consider essential factors such as the importance of minimum building envelope performance and the typically much shorter useful life of equipment. For similar reasons, we oppose performance path trade-offs for lighting and on-site generation (renewable or otherwise). Those who wish to take advantage of improved equipment and other such measures not otherwise covered by the code may use the ERI approach, where the efficiency of equipment and appliances, for example, are considered, since the ERI target value is set at an efficiency level that is intended to account for free ridership and other issues. Moreover, the ERI method contains crucial minimum back-stop envelope requirements (including meeting the 2015 prescriptive envelope requirements when on-site generation is used in the calculation).
8. Maintain and improve the 2018 IECC Commercial provisions.
We support the IECC as a stand-alone comprehensive energy code for all buildings, including all commercial buildings. However, some of the current IECC commercial building requirements are less stringent than ASHRAE 90.1-2016 (or, in the case of mechanical equipment, federal minimum requirements). Future IECC commercial building requirements should exceed where possible or, at a minimum, be at least as energy efficient overall as the latest version of ASHRAE 90.1 (plus any approved addenda). In the cases where the existing or proposed IECC requirements are more efficient or otherwise better than provisions in ASHRAE 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.
9. No product-specific provisions.
We oppose 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.
10. Independent testing, certification & labeling helps to ensure effective code compliance and enforcement.
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.
11. Energy efficiency provisions for existing buildings should be as robust as the provisions for new construction, to the maximum extent feasible.
We support improvements to the IECC and other International Codes to ensure that additions, renovations, replacements and repairs achieve reasonable energy efficiency.
12. No pride of authorship.
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.