Gas industry Comments on the International Energy Conservation Code (IECC) Commercial Public Comment Draft .
As reported in the September 30 End Use Codes and Standards Update , the Public Comment Draft #1 of the 2024 International Energy Conservation Code® Commercial Provisions was released for public comment and commentors had till today, Friday, October 21 to provide comments on the commercial provisions to the IECC. In response, AGA, the American Public Gas Association and National Propane Gas Association filed a joint comment, highlighted in red, on Section C101.3 Intent of the IECC as follows:
C101.3 Intent. This code shall regulate the design and construction of buildings for the effective use and conservation of energy over the useful life of each building. This code is intended to provide flexibility to permit the use of innovative approaches and techniques to achieve this objective. This code is not intended to abridge safety, health or environmental requirements contained in other applicable codes or ordinances or restrict the use of new materials, products, energy sources. or methods of construction.
Our rationale for the proposed change is as follows:
Proponents appreciate that the scope and intent of the IECC-C are solely set by the ICC Board of Directors. However, as almost half the country has adopted laws that prohibit discrimination of energy choice in building codes or other related regulations, proponents feel it is important for the IECC-C to reflect this same fuel neutrality. Such language will ensure that the IECC-C continues to be developed in a manner that will allow all jurisdictions the opportunity to adopt the code. If a formal request must be made to the ICC Board of Directors to consider this change, proponents will take such action, but we also wanted to put this proposal before the consensus committee, as ICC’s standard code development process typically requires a committee to consider a proposed change to scope/intent before going to the ICC Board of Directors for final consideration and approval (Procedures for ICC Consensus Committees, Section 9.4.c).
In addition to this proposed change, other proposals in support of the IECC Committee actions, proposal to replace the term fossil fuel with fuel gas, etc. were also submitted by AGA and gas industry interest. We will provide updates on this proposal as well all other proposed changes as the IECC code development process continues. Note that when finalize, all approved changes will be incorporated into the 2024 Edition of the International Energy Conservation Code.