RECA Public Comments to West Virginia State Fire Commission on 2009 IECC
Publication Date:
Friday, June 12, 2009
Summary:
On June 12, 2009, the Responsible Energy Codes Alliance submitted public comments to the West Virginia State Fire Commission regarding the state's prospective adoption of the 2009 IECC.
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June 16, 2009
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VIA E-MAIL
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Sterling Lewis, Jr.
Fire Marshal
West Virginia State Fire Commission
1207 Quarrier Street, 2nd Floor
Charleston, WV 25301
Re: Comments of the Responsible Energy Codes Alliance (RECA) Supporting Adoption of the 2009 International Energy Conservation Code (IECC)
Dear Mr. Lewis:
The Responsible Energy Codes Alliance supports the adoption of the 2009 IECC for residential and non-residential construction in West Virginia, as noticed May 22, 2009 in the West Virginia State Register. We believe the 2009 IECC should be an integral part of the state’s energy future, and the proposed rule will bring about a more consistent, more efficient set of energy requirements. We also recommend two editorial changes to the proposed rule that should add further clarity.
RECA is a broad coalition of energy efficiency advocates, product and equipment manufacturers, trade associations, and regional organizations administered by the Alliance to Save Energy. A list of RECA’s members is included at the end of this letter. Our primary mission is to urge all states and localities to adopt the most recent version of the IECC without substantive weakening amendments.
The proposed rule increases energy efficiency and simplifies compliance with and enforcement of the energy code. It also follows through on Governor Manchin’s commitment to revise the energy codes in order to receive $32,746,000 in State Energy Program funds under the 2009 American Recovery and Reinvestment Act (Stimulus Bill). http://www.energy.gov/media/3154ManchinWestVirginia.pdf
The proposal adopts the 2009 International Codes, including the IECC and International Residential Code (IRC), and deletes Chapter 11 of the IRC to ensure that all construction – residential and non-residential – meets the requirements of the IECC. (This approach has been used successfully in a number of states.) The proposal also eliminates an outdated state-specific
compliance option that conflicts with the national model code. These simple changes will keep West Virginia on track with the national model energy code and will bring a number of energy-saving and cost-saving benefits to the state’s citizens.
We recommend two editorial changes that we believe are consistent with the intent of the rule and will provide added clarity for code officials. First, Section 4.1.7.A should reference the 2009 IRC, which was adopted by reference in Section 4.1.7. Second, Section 4.1.7.A should clarify that the adoption of the 2009 IECC and the deletion of IRC Chapter 11 means that all construction should meet the energy requirements of the 2009 IECC. An edited version of the paragraph would read as follows:
4.1.7.A. Chapter 11 of the 20039 edition of the International Residential Code for One and Two Family Dwellings, Seventh First Printing, entitled “Energy Efficiency”, is deleted and not considered to be a part of this rule. In lieu thereof, the following standards are adopted and made a part of this rule: Compliance with this chapter shall bedemonstrated by meeting the requirements of the 2009 International Energy Conservation Code.
West Virginia Will Benefit from Adopting the 2009 IECC as the Single Energy Efficiency Code for the State.
· The adoption of the 2009 IECC was designated by Congress as a specific requirement for states to receive $3.2 billion in State Energy Program funds through the Stimulus Bill.
· The 2009 IECC is the final product of a code development process that involved the nation’s leading experts in energy efficiency, building design and product performance, state and local code officials, product manufacturers and homebuilders. Customers are demanding energy efficient or “green” building, and are willing to pay more for these homes, even in a slumping housing market. Builders gain credibility by following the latest national energy standards.
· Statewide implementation and enforcement of the 2009 IECC will ensure that every buyer of a new home gets one that is sensibly efficient. A home built to the 2009 IECC will have an efficient duct system, a well-sealed thermal envelope, a programmable thermostat, and a properly-sized heating and cooling system.
· By adopting the 2009 IECC, West Virginia will stay on track with statewide energy efficiency goals and will guarantee homeowner benefits for many years. New construction is the most cost-effective time to install good insulation, quality windows and doors, and efficient heating and cooling equipment. Construction costs will be reduced through economies of scale, as suppliers and retailers may reduce inventories and streamline production to meet more consistent energy targets.
· The 2009 IECC will facilitate compliance and enforcement of the code, and will allow builders to take advantage of free Department of Energy trainings, free compliance software like REScheck, and other programs. These programs do not apply to the IRC or any state-created energy codes.
The Proposed Rule Correctly Replaces the Outdated State-Specific Compliance Option with a Reference to the IECC.
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The proposed rule eliminates a significantly weaker compliance option that conflicts with the IECC. For a number of reasons, the IECC is the best available option for an energy efficient code.
· The 2009 IECC is a more energy efficient and more robust code than Chapter 11 of the 2009 IRC or the alternative Chapter 11 currently in the State Building Code. While the IRC includes only a simple prescriptive option, the IECC includes several flexible compliance options that are designed to maintain efficiency.
· The IECC is the only code recognized in federal law and nationwide as the comprehensive model energy code for all residential and commercial buildings. More than two thirds of states have adopted the IECC as their mandatory statewide energy code.
· Under the federal Energy Policy Act of 1992, the US Department of Energy (DOE) is required to review each new version of the IECC and determine if it is an improvement in energy efficiency over previous versions. (IRC Chapter 11 does not undergo such a rigorous assessment by DOE, so it is not clear whether it would meet the same high standard for energy efficiency improvement.) States are also required by federal law to undertake a review of the state energy code and determine whether state energy efficiency requirements meet the stringency of the IECC every time the Department of Energy makes a determination on the updated IECC.
· The IECC also serves as the basis for federal tax credits for energy efficient homes, energy efficiency standards for federal buildings, and qualification for FHA mortgages. The IECC is also referenced in LEED and many other state and federal programs. As mentioned above, Congress designated the IECC as the threshold requirement for State Energy Program funds available under the Stimulus Bill. None of these programs even references the IRC.
Conclusion
Building efficiency is a key component to the state’s efforts to secure its energy future. RECA supports West Virginia’s incorporation of the 2009 IECC for both residential and non-residential construction. These simple changes will ensure that the state qualifies for Stimulus funding and will save homeowners (and the state) money in energy savings for many years to come.
Respectfully Submitted,
OCEAN Resource:
OCEAN Approved