Report on the BECS Committee Meeting of September 25 – 26, 2024, in San Antonio, Texas. 

Thanks to everyone who attended in-person or participated virtually in this week’s very productive, BECS Committee Meeting of September 25 – 26, 2024, held in San Antonio, Texas .  The draft minutes of the meeting will be sent out in the near future.  All presentation material made at the BECS meeting will be posted on the BECS Committee site soon. This will include the slides and presentations from the Introduction to Gas Heat Pumps, from the North American Gas Heat Pump Collaborative (NAGHPC) and an overview of Modern Hydrogen’s pyrolysis product for clean hydrogen production and carbon capture, etc.

International Code Council (ICC)  Issues the 2027 International Energy Conservation Code (IECC) Scope and Intent and Board Commentary, Calls for Proposals on the 2027 IECC by December 9, 2024.

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 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, Intent and Commentary can be found at this link. This draft was open for public comment until Monday, August 19, 2024.

Following a distribution of a draft AGA response to the ICC request for comments on the proposed changes to the Scope and Intent and a request of the BECS Committee feedback, AGA developed and submitted the attached response to the ICC request. The comments capture specific concerns and outline recommendations that we believe if adopted, will improve the proposed ICC Scope and Intent and result in a clear and comprehensive understanding of the IECC’s Scope and Intent. Specifically, the AGA recommendations call for improvements in providing a more open and transparent process, including following due process for proper model consensus code development, etc.  The recommendations are intended to help ensure that in the development of the 2027 IECC, the process problems that caused excessive confusion and delays, resulting in the need to file appeals on the 2024 IECC that were primarily successful will not be necessary. Of primary concerns,  the AGA comments requested that the Scope and Intent be clear that the provisions in the IECC including the Non-Mandatory Appendix provisions are directed specifically for improving the built environment covered in the IECC and is for reducing energy consumption and improving the energy efficiency of the residential and commercial structures covered by the code.  Unfortunately, it appears that all public comments submitted to the IECC request for comments on the draft Scope, Intent and 

On Tuesday , the ICC issued the final 2027 IECC Scope, Intent and Board Commentary posted it here.  Unfortunately, an initial  review of the final 2027 IECC Scope, Intent and Board Commentary reveals that the version did not make any substantive changes to the draft and essentially ignored the AGA recommendations that would have essentially resolved much of the confusion as well as what can (energy consumption) and what could not (green house gases) be included in the provisions of the energy code.  AGA believes that while there was some improvement and clarification to the Scope and Intent draft document especially on fuel neutrality, the continued allowance to permit provisions that are outside of the basic intent of the energy code will continue to permit requirements that don’t impact energy consumption, and apparently they are not  required to meet the same requirements such as energy consumption reductions, etc. will still be permitted to be included in the IECC provisions. We believe that this will certainly add confusion to the provisions in the IECC, as well as added cost with no benefit to reducing energy consumption to homes and buildings that include these provisions in their compliance requirements.

Also today related to the 2027 IECC development, ICC staff announce that “The 2024 IECC, Chapter 11 of the International Residential Code and the Energy Appendices of the International Residential Code with the updated scope and intent will open for public comment on October 7, 2024, and run through December 9, 2024.  This is the link of the announcement in the Building Safety Journal.  Note that the consensus committee rosters will not be announced until the end of October.“

At this week’s BECS Committee meeting and in anticipation of the opening up of this comment period, the committee established a Task Group to develop and prepare draft proposals to the 2027 IECC and will be meeting over the coming weeks to outline the proposals. All BECS Committee members interested in participating on this Task Group are invited to participate in this newly formed Task Groups meetings and should contact BECS staff on your desire to participate and can also submit recommendations on suggested needed changes to us.