RESNET has submitted comments to the U.S. Department of Energy in response to its Request for Information, “Updating and Improving the Methodology for Assessing Affordability and Cost-Effectiveness of Building Energy Codes” (Docket No. EERE-2026-BT-BC-0034). The RFI seeks public input on how DOE evaluates the consumer impacts, costs, energy savings, affordability, and cost-effectiveness of residential and commercial building energy codes. In its comments, RESNET encourages DOE to recognize verified, performance-based compliance pathways — including the HERS® Index and the IECC Energy Rating Index compliance alternative — as practical tools for improving affordability, consumer choice, and real-world energy performance. RESNET emphasizes that independent third-party verified ratings provide builders flexibility to select the most cost-effective compliance solutions while ensuring that projected energy savings are achieved in the field. RESNET also highlights successful state-level implementation, including Texas’s optional HERS-based compliance pathway, as evidence that market-driven, verified performance approaches can increase builder participation, improve energy outcomes, and support housing affordability without relying on rigid prescriptive mandates. Additionally, RESNET recommends that DOE incorporate HERS Registry data, verified compliance, and the market mechanisms unlocked by energy ratings — such as utility programs, federal incentives, and mortgage-related tools — into its methodology for evaluating building energy codes. RESNET encourages its members, rating companies, builders, program partners, and other stakeholders to submit their own comments to DOE before the August 3, 2026 deadline. Comments may be submitted through Regulations.gov under Docket No. EERE-2026-BT-BC-0034 or by email to BldgEnergyCodesMethodology2026BC0034@ee.doe.gov. Your input can help ensure that DOE’s methodology reflects real-world construction practices, verified performance, affordability, and consumer choice. Click on RESNET DOE Comment Letter to view RESNET’s comments. Click on DOE Comment Page to submit your comments.
