2027 IECC Commercial and Residential Scope and Intent Draft for Public Comment and IECC Committee Membership are Due August 19.

Back on May 10, we reported that  AGA, the American Public Gas Association (APGA), and the National Propane Gas Association (NPGA) filed joint comments (attached),  to  the International Code Council (ICC) on a number of recommendations to improve the development and appeals process for the International Energy Conservation Code–Commercial, International Energy Conservation Code – Residential, and International Residential Code – Chapter 11 (collectively, “IECC”).  These comments were  in response to a call for comment regarding the development process, appeals process, and scope and intent of the IECC in the ICC  April 11th Building Safety Journal  (BSJ) article requesting feedback on the IECC development and appeals process that was recently completed for the 2024 Edition of the IECC. Also recall that numerous articles on the 2024 IECC development have been provided in the BECS “Update on End Use Codes and Standards” weekly reports and the joint comments were submitted with the intent of providing constructive recommendations that if adopted by the ICC, will avoid the extensive controversy, and appeals that occurred in developing the 2024 Edition of the IECC.  The IECC is a very important document, cited in federal law and a variety of other programs that impacts energy choices, and requirements for construction for the residential and commercial built environment. Improvements in the development and appeals process will go a long way to avoid the problems and delays that occurred during the 2024 IECC edition development.

In response to the comments received on its request,  the “International Code Council Board of Directors has developed a draft scope and intent for the 2027 International Energy Conservation Code® (IECC®) based on feedback they received on the 2024 IECC appeals process. Accompanying this draft is a commentary provided by the Board of Directors on the revisions made to the scope and intent. The draft scope and commentary can be found at this link. This draft will be open for public comment until Monday, August 19, 2024, at 11:59 pm Pacific Time. Public comment will be accepted through the following form.”  Following review and consideration of the public comments, the Board of Directors will then set the final scope and intent statements for the 2027 IECC. Note also that the ICC is “ now accepting applications for IECC Consensus Committee membership for the 2027 code development cycle. The application can be accessed through the following link. Applications will be accepted until Monday, August 19, 2024, at 11:59 pm Pacific Time. Applications for subcommittee voting members will be open in the coming months.

In reviewing the draft “Commentary and Direction from the Board of Directors” for both the Residential and Commercial 2027 IECC, the following is provided:

• The code shall provide a minimum base energy code with prescriptive and performance-based pathways that take into consideration feasibility of technology and costs impacts to building owners and occupants
• Provisions of the code shall not promote or penalize specific types of equipment or fuel sources.
• The code will aim to simplify code requirements to facilitate the code’s use and compliance rate. The code is updated on a three-year cycle with each subsequent edition providing increased energy savings over the prior edition.
• This code is intended to provide flexibility to permit the use of innovative approaches and techniques to achieve this intent. This code is not intended to abridge safety, health or environmental requirements contained in other applicable codes or ordinances.
• Provisions that provide for greenhouse gas reductions or resilience benefits (e.g., electric vehicles, readiness, demand response, and onsite or off-site energy storage or renewable energy) as well as provisions to achieve zero energy buildings shall only be included either in an optional appendix/appendix or as part of a compliance path (e.g., credits system, simulated performance) where compliance is still possible without using or promoting such measures (e.g., through strictly energy efficiency measures).

We are encouraged that the ICC Board “Commentary and Direction”,  states that the “ Provisions of the code shall not promote or penalize specific types of equipment or fuel sources”.  We  do have concerns that they also are recognizing that “greenhouse gas reductions  or resilience benefits (e.g., electric vehicles, readiness, demand response, and onsite or off-site energy storage or renewable energy) as well as provisions to achieve zero energy buildings shall only be included either in an optional appendix/appendix or as part of a compliance path (e.g., credits system, simulated performance) where compliance is still possible without using or promoting such measures (e.g., through strictly energy efficiency measures)”. Recall that in developing the 2024 Edition of the IECC the major concern was the inclusion of adding provisions such as electric ready, Electric Vehicle provisions etc., that did not improve the energy efficiency of the home or building, added cost and complexity, etc. were a cause for a number of successful appeals that the ICC Board did agree did not belong in the IECC and were deleted as a result of the appeals. Continuing to include them, and even in a non-mandatory section does not appear to be justified since they do not improve the energy efficiency of the structure, the specific purpose of the IECC. Additionally, including them within the IECC would encourage states and/or jurisdictions to adopt them as mandatory provisions.

BECS committee members are requested to let us know if you are interested in serving on either the Residential or Commercial IECC and to review the draft Scope and Intent and provide us with your feedback by August 2nd.

State Codes Activity Update.

Attached is a weekly feature of the “Friday Update” covering state code calendar activities as presented by the online utility “Fiscal Note,” which is sponsored by APGA and AGA Code and Standards. Please review the update and determine if there are state code activities that impact your service territory or organization.