The International Energy Conservation Code (IECC) Committee Action Hearings—an event that’s so exciting, it can only happen once every three years! During the last week of April and the first week of May 2019, RESNET participated in the residential IECC Committee Hearings in Albuquerque, New Mexico. After identifying 37 proposals for the RESNET Board to review, the Board narrowed down RESNET’s priorities to 13 proposals. This blog will look at the outcomes of some of those proposals and other notable committee decisions. Brief Background on the Code Development Process All of the International Code Council’s (ICC) model codes are up for revision every three years. Anyone is eligible to submit a code change proposal to ICC. The first big step in the review process is the Committee Action Hearing. The Residential Energy Committee is an 11-member group responsible for making recommendations on each proposal. If a code change is recommended for approval by the committee, it only requires a simple majority during the governmental member consensus voting process to be approved (in November). Proposals recommended by the committee for disapproval are still eligible to be approved by the ICC membership but require a two-thirds majority to overturn the committee’s action. The second big step in the process is the Public Comment Hearings. Any proposal is subject to public comment during the public comment window. All proposals that receive a comment will be on the agenda for the public comment hearings. After the public comment hearings, there is an online vote of all governmental members of ICC (primarily state/local code officials). This vote determines the final changes that make it into the next code edition. RESNET’s Role in the Committee Action Hearings RESNET was primarily focused on supporting proposals that allow our standards to be used in the IECC as well as proposals that maintain the integrity of the Energy Rating Index (ERI) Compliance Path. RESNET primarily opposed proposals that would diminish the usability of the ERI path or diminish the role of raters in the code compliance verification process. RESNET’s Successes An early success for RESNET was the approval of the update of Standards 301 and 380 to the 2019 versions by the Administrative Committee. Barring any mishaps at the public comment hearings, the 2021 IECC will include reference to the most current versions of Standards 301 and 380. In another success that faced no opposing testimony was proposal RE114 which will reference Standards 380 and ASTM E1554 for duct leakage testing. Although Standard 380 is referenced for building envelope leakage testing in the 2018 IECC, it didn’t make it into the 2018 code for duct leakage testing. RESNET was also successful in defeating proposal RE152—which would have made the performance path very similar to the ERI path. The primary reason for opposing this proposal was to keep the performance path and ERI path as their own distinct compliance paths, each with its own unique benefits. Another success was defeating RE184 which would have limited the reduction of energy use for renewable energy to a maximum of 5% of total energy use. RESNET’s primary reason for opposing this proposal was that it would have made the ERI path and HERS® index diverge even further. RESNET believes that the further the ERI and HERS® Index scores diverge the less likely it is that the ERI will be used for code compliance. RESNET’s Defeats The first disappointing committee decision came with proposal RE183. This was a RESNET proposal to delete the change that made it into the 2018 code that revises the ventilation rate for the reference home in the ERI path. This was one of a number of ventilation-focused changes that were disapproved by the committee. In another disappointing decision, the committee approved proposal RE186 which revised the bad ventilation language from the 2018 IECC to refer back to the Section R405-Performance Path ventilation rate. The ventilation rate referenced in the performance path is the same as was included in the 2018 IECC which essentially keeps the 2018 language for ventilation rate in the reference home. Unfortunately, if this language is upheld during the public comment hearings and online governmental consensus vote, it will mean the index scores under the 2021 IECC, section R406, and HERS® Index scores are not the same. RESNET submitted three proposals that attempted to plug holes in the ERI path related to quality assurance and documentation. The first two were RE197 and RE200. These two would have ensured that third parties that are verifying compliance with the ERI path were working under the auspices of a rating provider as defined in Standard 301. Both were intended to clarify a misconception that the ERI compliance path has quality assurance associated with it. Unfortunately, the ERI path only has QA if a home is submitted to RESNET as a HERS® rating. The committee chose to disapprove both of these proposals. The third proposal, RE201, would have specified the documentation needed to obtain a certificate of occupancy. Unfortunately, the proposal did reference third parties working under a quality assurance provider, as included in the previous two proposals and was disapproved. However, proposal RE205, submitted by Robby Schwarz of Energy Logic was approved by the committee and includes the documentation required to obtain a permit and certificate of occupancy under the ERI path. There were numerous proposals that would have introduced an optional path to net zero energy using the ERI path. All of these proposals were disapproved by the committee. In addition, there were a few proposals attempting to reference the insulation grading criteria from the 2019 version of Standard 301. These proposals were also disapproved by the committee. One Surprise Worth Noting… Proposal RE17 which proposes a new compliance path based on Btu targets for heating and cooling loads for each climate zone was approved by the committee. A similar proposal was brought forward during the 2018 code update process and was disapproved. RESNET is weighing the pros and cons of this concept and may submit public comments on RE17. Closing Thoughts Overall, the 2021 IECC Residential Energy Committee played it safe. No real significant changes were approved. Ultimately, it will be up to the ICC Governmental Voting members to determine what makes it into the 2021 IECC during the online consensus vote in November of this year. RESNET will be considering all actions taken by the committee, and preparing public comments accordingly.
