iecc - residential irc - energy

2016 GROUP B COMMITTEE ACTION HEARINGS

APRIL 17, 2016 – APRIL 27, 2016 KENTUCKY INTERNATIONAL CONVENTION CENTER LOUISVILLE, KY

IECC - ResidentialIRC - Energy

ICC COMMITTEE ACTION HEARINGS ::: April, 2016 RE1

First Printing

Publication Date: March 2016

Copyright © 2016 By

International Code Council, Inc.

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2016 GROUP B – PROPOSED CHANGES TO THE INTERNATIONAL ENERGY CONSERVATION CODE AND

INTERNATIONAL RESIDENTIAL CODE - ENERGY

INTERNATIONAL ENERGY CONSERVATION CODE COMMITTEE – RESIDENTIAL

AND INTERNATIONAL RESIDENTIAL CODE COMMITTEE

- ENERGY Helen Kessler DiFate, AIA, Chair President DIFATE GROUP, PC St. Louis, MO

Kirk Nagle, Vice Chair Plan Examiner City of Aurora Public Works Department-Building Division Aurora, CO

Gerald Anderson, MCP Assistant Codes Administrator City of Overland Park Overland Park, KS

Matt Belcher, CGP Rep: National Association of Home Builders Verdatek Solutions Wildwood, MO

Michael Malatino Superintendent of Buildings and Public Works Inc. Village Old Westbury Old Westbury, N.Y.

Randall K. Melvin Rep: National Association of Home Builders Randy Melvin’s High Performance Building and Code Solutions, LLC New Market, MD

Thomas Marston, RESNET, BPI, BA, EP Rep: National Association of Home Builders Energy Services Group Glen Burnie, DE

Gerald K. Peterson HVAC/Energy Program Manager Idaho Division of Building Safety Meridian, ID

Richard Potts II Senior Construction Inspector II Virginia Department of Housing Community Development Richmond, VA

Jim Zengel, CGB, CGP Rep: National Association of Home Builders Zengel Construction Co Dayton, OH

Staff Secretariat: Fred Grable, PE Senior Staff Engineer - Plumbing International Code Council Central Regional Office Country Club Hills, IL


TENTATIVE ORDER OF DISCUSSION 2016 PROPOSED CHANGES TO THE

INTERNATIONAL ENERGY CONSERVATION CODE – RESIDENTIAL

AND INTERNATIONAL RESIDENTIAL CODE - ENERGY

The following is the tentative order in which the proposed changes to the code will be discussed at the public hearings. Proposed changes which impact the same subject have been grouped to permit consideration in consecutive changes.

Proposed change numbers that are indented are those which are being heard out of numerical order. Indentation does not necessarily indicate that one change is related to another. Proposed changes may be grouped for purposes of discussion at the hearing at the discretion of the chair. Note that some RE code change proposals may not be included on this list, as they are being heard by another committee.

NUMBERS NOT USED RE62-16 RE88-16 RE93-16

ADM1-16 Part III CE2-16 Part II RE3-16

CE1-16 Part II CE3-16 Part II ADM2-16 Part III ADM6-16 Part III ADM4-16 Part III CE4-16 Part II CE5-16 Part II ADM9-16 Part III CE7-16 Part II CE272-16 Part II CE8-16 Part II CE11-16 Part II G9-16 Part II

RE4-16 RE5-16 RE6-16

CE13-16 Part II ADM16-16 Part III CE14-16 Part II

RE7-16 RE8-16 RE9-16

CE18-16 Part II ADM26-16 Part III

ADM35-16 Part III G14-16 Part III G10-16 Part III

RE11-16 CE38-16 Part II

CE23-16 RE12-16

RE16-16 RE13-16 RE14-16 RE15-16 RE17-16 RE18-16 RE19-16 RE20-16 RE21-16 RE22-16 RE23-16 RE24-16 RE25-16 RE26-16 RE27-16 RE28-16 RE29-16 RE30-16 RE31-16 RE32-16

RE33-16 RE34-16 RE35-16 RE36-16 RE37-16 RE38-16 RE39-16 RE40-16 RE41-16 RE42-16 RE43-16 RE44-16 RE45-16 RE46-16 RE47-16 RE48-16 RE49-16 RE50-16 CE84-16 Part II RE51-16 RE52-16 CE65-16 Part II RE53-16 RE54-16 CE86-16 Part II RE55-16

CE87-16 Part II

RE56-16 RE57-16 RE58-16 RE59-16 RE60-16 RE61-16 RE63-16 RE64-16 RE65-16 RE66-16 RE67-16 RE68-16 RE69-16 RE70-16 RE71-16 RE72-16 RE73-16 RE74-16 RE75-16 RE76-16 RE77-16 RE78-16 RE79-16 RE80-16 RE81-16 RE82-16 RE83-16


RE84-16 RE85-16 RE86-16 RE87-16 CE106-16 Part II RE89-16

CE137-16 Part II RE90-16 RE91-16 RE92-16

CE115-16 Part II CE114-16 Part II

RE94-16 RE95-16 RE96-16 RE97-16 RE98-16

CE134-16 Part II CE135-16 Part II CE169-16 Part II

RE99-16 RE100-16

CE147-16 Part II RE101-16 RE102-16 RE103-16 RE104-16 RE105-16 RE106-16 RE107-16 RE108-16 RE109-16 RE110-16 RE111-16 RE112-16 RE113-16

RE191-16 CE175-16 Part II RE114-16 RE115-16 RE116-16 RE117-16 RE118-16 RE119-16 RE120-16 RE121-16 RE122-16 RE123-16

RB271-16 Part II RE124-16

CE177-16 Part II CE176-16 Part II

RE125-16 RE126-16 RE127-16 RE128-16

CE174-16 Part II RE129-16 RE130-16 RE131-16 RE132-16 RE133-16 RE134-16 RE135-16 RE136-16 RE137-16 RE138-16 RE139-16 RE140-16 RE141-16 RE142-16 RE143-16 RE144-16 RE145-16 RE146-16 RE147-16 RE148-16 RE149-16 RE150-16 RE151-16 RE152-16 RE153-16 RE154-16

CE259-16 Part II RE155-16 RE156-16 RE157-16 RE158-16 RE159-16 RE160-16 RE161-16 RE162-16 RE163-16 RE164-16 RE165-16 RE166-16 RE167-16

CE248-16 Part II RE168-16 RE169-16 RE170-16 RE171-16 RE172-16 RE173-16 RE174-16 RE175-16 RE176-16 RE177-16 RE178-16 RE179-16 RE180-16 RE181-16

RE182-16 CE274-16 Part II

CE275-16 Part II RE183-16 RE184-16 RE185-16 RE186-16 RE187-16 RE188-16 RE189-16

ADM93-16 Part III RE1-16 ADM 43-16 Part II ADM42-16 Part II ADM45-16 Part II CE157-16 Part II ADM61-16 Part III ADM59-16 Part III ADM60-16 Part III ADM62-16 Part III ADM46-16 Part II ADM47-16 Part II ADM54-16 Part II RE2-16 ADM56-16 Part II ADM57-16 Part II ADM82-16 Part III ADM84-16 Part II ADM58-16 Part III ADM80-16 Part III CE 21-16 Part II CE22-16 Part II CE26-16 Part II CE27-16 Part II CE33-16 Part II CE31-16 Part II CE30-16 Part II

RE190-16 CE28-16 Part II CE25-16 Part II CE24-16 Part II CE29-16 Part II CE10-16 Part II

RE10-16 RB373-16


RE1-16 : IRC N1101.1-SIVIGNY12599

RE1-16IRC: N1101.1, N1101.1.1 (New)Proponent : Donald Sivigny, representing Association of Mn Building Officials ([email protected])

2015 International Residential CodeRevise as follows:

N1101.1 Scope. This chapter regulates the energy efficiency for the design and construction of buildings regulated by thiscode.

Note: The text of the following Sections N1101.2 through N1105 is extracted from the 2012 edition of the InternationalEnergy Conservation Code—Residential Provisions and has been editorially revised to conform to the scope andapplication of this code. The section numbers appearing in parenthesis after each section number are the sectionnumbers of the corresponding text in the International Energy Conservation Code—Residential Provisions.

Add new text as follows:

N1101.1.1 Criteria. Buildings shall be designed and constructed for energy conservation in accordance with the InternationalEnergy Conservation Code--Residential Provisions.

Reason: When the f inal action hearings w e held for the 2012 IRC, the membership almost unanimously (it w as at 97% to 98%) voted to remove theEnergy Chapter, Chapter 11 , from the provisions of the IRC and replace it w ith a reference to the IECC residential chapters (RE). There continues tobe consistency issues and confusion by the user of the code , in their understanding of w hich provisions they are to use for residential buildings. Dothey follow the IECC RE chapters 1-5, or do they follow the editorialized language from Chapter 11 in the IRC. The code itself in Section N1101.1 of theIRC states that "Sections N1101.2 through N1105 of the IECC residential provisions has been editorially revised." What does that actually mean, andhow do w e enforce editorial changes, especially from a legal standpoint. We can't enforce someone's editorial language; w e can only enforce theminimum requirements of the code, not someone's opinion. We alw ays w ere under the impression that the editorial portion of the code w as w hat thecommentary books are used for. Why change it now ? Chapter 11 also lists the corresponding sections of the IECC. Therefore to properly enforce to orbuild to Chapter 11 of the IRC, both the code off icial and the builder w ill need to use both residential provisions out of the IRC and IECC for construction,plan review and inspections of residential buildings. This adds extra time in design, plan review , and inspections. It is time to make the changes asw anted by the membership for the 2012 Code, get the opinions out of the documents and leave them in the commentaries w here they belong, and stopall the confusion. This just makes good f inancial and common sense.

Cost Impact: Will not increase the cost of constructionThe f inancial impact on this is a cost savings in printing materials, and time that is w asted by ICC, builders, and building off icials, w ho w ill need to utilizeresidential energy provisions in tw o different codes.

Analysis: Code change proposal RE1-16, to be considered by the Residential Energy Committee, addresses the scope and application of theInternational Residential Code and the International Energy Conservation Code. The f inal action taken on code change proposal RE1-16 w ill be limitedto an advisory recommendation to the ICC Board of Directors w ho w ill determine the f inal disposition on this proposed change in accordance w ithSection 1.3 of CP 28, w hich stipulates that the Board determines the scope of the I-Codes.


RE2-16 : R103.2.1-GIESZLER10917

RE2-16R103.2.1 (IRC N1101.5.1)Proponent : Michael Gieszler, representing Oregon Building Officials Association ([email protected])

2015 International Energy Conservation CodeRevise as follows:

R103.2.1 (N1101.5.1) Building thermal envelope depiction. The building's thermal envelopeDetails representing eachunique assembly making up the building's thermal envelope including floors, walls and ceilings or attics shall be represented provided on the construction documents drawings.

Reason: Clarif ies that each unique assembly of the thermal envelope must be show n on the draw ing in suff icient detail to determine compliance.

Cost Impact: Will not increase the cost of constructionThis change is almost editorial in nature and simply provides clarity to the code section. No additional materials or labor are required and therefore, thereis not an increase in the cost of construction.


RE3-16 : R202-AIR-IMPERMEABLEINSULATION-SCHWARZ12371

RE3-16R202Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])

2015 International Energy Conservation CodeAdd new definition as follows:

SECTION R202 DEFINITIONS

AIR-IMPERMEABLE INSULATION. An insulation having an air permability of equal to or less than 0.02 L/s-m2 at 75 Papressure differential when tested in accordance with ASTM E2178 or E283.

Reference standards type: This is an update to reference standard(s) already in the ICC Code Books Add new standard(s) as follows: ASTM E2178-13 Standard Test Method for Air Permeance of Building MaterialsReason: Definition carried over from the IRCThe term air permeable insulation is utilized in the IECC specif ically in Table R404.1.1. Carrying this definition over to from the IRC to the IECC helpsclarify w hat can and cannot be used in specif ic installation according to the code.

Cost Impact: Will not increase the cost of constructionThere w ould be no cost impact associated w ith this proposed definition as it is being added to create better consistency betw een the code families andclarity for the intent of the current code.

Analysis: The term is defined in IRC Chapter 2.The standard proposed for inclusion in this code, ASTM E2178-13, is referenced in the International Energy Conservation Code-CommercialProvisions.


RE4-16 : R202-HIGH-EFFICACYLAMPS-NORMAN11831

RE4-16R202 (IRC N1101.6)Proponent : Phillip Norman, representing self ([email protected])

2015 International Energy Conservation CodeSECTION 202 DEFINITIONS

HIGH-EFFICACY LAMPS. Compact fluorescent lamps, T-8 or smaller diameter linear fluorescent lamps, or lampsLight emitting diode (LED) downlights with a minimum efficacy of:

1. Sixty lumens per watt for lamps over 40 watts;2. Fifty lumens per watt for lamps over 15 watts to 40 watts; and3. Fourty lumens per watt for lamps 15 watts or less.

luminaire beam angle 90° to180°, and with correct color illumination to the human eye.

Reason: CFLs can not compete w ith LEDs as directional task illumination. Directional CFLeff icacy can not exceed 50 lumens per w att, and CFLs can not match LED endurance andperformance, as in dimmability. Poor CFL dimmability adds to their operating cost. DiscouragingCFL manufacturing w ill reduce mercury content lost to the environment in disposal. Point-sourcelighting is excluded from high-eff icacy promotion, as alw ays about half as eff icient as directionallight correctly aimed.Concentrated spot lighting is excluded, as suited to purposes of decor and commerce not generalto public good. The exclusion w ill guide against use of less-safe spot lighting for moving-taskillumination. The definition for energy conservation need not include needs of concentration as inautomobile headlights.

Correct color illumination to the human eye w ill occur for phosphor-coated LEDs at colortemperature from 2700°K to 3300°K. Blue LEDs more-eff icient w ith lesser coating, are nothigh-eff icacy.

Cost Impact: Will not increase the cost of constructionThere are temporary added costs in advances of technology, as in giving up CRT television and computer displays, w ith w ell-founded assurance ofimmediate improved happiness. The transition in lighting is w ith yet-greater promise of savings.


RE5-16 : R202-HIGH EFFICACYLAMPS-ROSENSTOCK11866

RE5-16R202 (IRC N1101.6)Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])


R202 (N1101.6) HIGH-EFFICACY LAMPS. Compact fluorescent lamps, light emitting diode (LED) lamps, T-8 or smallerdiameter linear fluorescent lamps, or other lamps with a minimum efficacy of:


Reason: This proposal clarif ies the definition to include LED lamps and other lamp technologies that may be used (such as induction lighting or otherlighting technology).

Cost Impact: Will not increase the cost of constructionThis proposal only ciarif ies the definition and does not change any code requirements.


RE6-16 : R202-HIGH-EFFICACYLAMPS-WILLIAMS12247

RE6-16R202 (IRC N1101.6)Proponent : Jeremiah Williams ([email protected])


R202 (N1101.6) HIGH-EFFICACY LAMPS. Compact fluorescent lamps, T-8 or smaller diameter linear fluorescent lamps, orlampsLamps with a minimum efficacy of:


75 lumens per watt.

Reason: The w ide availability and falling prices of LED lamps makes them a cost-effective option for improving residential eff iciency. The proposedthreshold of 75 lumens/Watt encourages the use of the new technologies w hile still permitting many better CFL technologies.

Energy Savings: DOE conducted an energy analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.1 In analyzing the energy cost savings and cost-effectiveness of this codechange proposal, DOE evaluated the option of replacing all CFLs (luminous eff icacy of 55 lumens/w att) w ith LEDs (luminous eff icacy of 78lumens/w att). The energy analysis indicates that LEDs save about $6 per year in overall energy costs across all climate zones. This represents 0.22%to 0.75% of IECC-regulated end uses (heating, cooling, lighting and w ater heating), depending on climate zone.

The U.S. Department of Energy (DOE) develops its proposals through a public process to ensure transparency, objectivity and consistency in DOE-proposed code changes. Energy savings and cost impacts are assessed based on established methods and reported for each proposal, as applicable.More information on the process utilized to develop the DOE proposals for the 2018 IECC can be found at:https://w w w .energycodes.gov/development/2018IECC.

Bibliography:

1. Taylor, ZT; Mendon, VV; and Fernandez, N. (2015). Methodology for Evaluating Cost-Effectiveness of Residential Energy Code Changes. Pacif ic Northw est National Laboratory for U.S. Department of Energy; Energy Eff iciency & Renew able Energy. PNNL-21294 Rev1. https://w w w .energycodes.gov/development/residential/methodology.

2. See http://w w w .mckinsey.com/insights/energy_resources_materials/peering_into_energys_crystal_ball?cid=other-eml-alt-mkq-mck-oth-15073. Preliminary Technical Support Document: Energy Eff iciency Program for Consumer Products and Commercial and Industrial Equipment: General

Service Lamps. U.S. Department of Energy. December 1, 2014.4. J. Tuenge. "SSL Pricing and Eff icacy Trend Analysis for Utility Program Planning." Pacif ic Northw est National Laboratories for U.S. Department

of Energy; Energy Eff iciency & Renew able Energy, October 2013. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_trend-analysis_2013.pdf.

Cost Impact: Will increase the cost of construction This change w ill increase the cost of construction because it requires higher eff icacy lighting (lamps and/or f ixtures), w hich w ill likely eliminate somelow er-end CFL options and/or push builders to new er LED technologies. The cost of LEDs has been steadily declining over the last several years andis expected to continue to decline betw een now and the publication of the 2018 IECC. Based on current price estimates and projected price reductionsas the LED market matures, this analysis assumes that in 2018 LEDs w ill cost $4.84 per lamp compared to CFLs at $3.10 per lamp.2,3,4

Cost-effectiveness: DOE conducted a cost-effectiveness analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.1 The analysis indicates life-cycle cost savings in all climate zones, ranging fromabout $33 to $63. The full analysis is available at https://w w w .energycodes.gov/sites/default/f iles/documents/iecc2018_R-5_analysis_final.pdf.


https://www.energycodes.gov/development/residential/methodology

https://www.energycodes.gov/development/2018IECC


http://www.mckinsey.com/insights/energy_resources_materials/peering_into_energys_crystal_ball?cid=other-eml-alt-mkq-mck-oth-1507

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_trend-analysis_2013.pdf


https://www.energycodes.gov/sites/default/files/documents/iecc2018_R-5_analysis_final.pdf

RE7-16 : R202-ON-SITE PRODUCTION(NEW)-LOVELL13034

RE7-16R202 (New) [IRC N1101.7 (New)]Proponent : Vickie Lovell, InterCode Incorporated, representing Leading Builders of America ([email protected])


R202 (N1101.7) ON-SITE POWER PRODUCTION Electric power produced at the site shall be the net electrical powerproduction, such that it equals the gross electrical power production minus any purchased fossil fuel energy used to producethe on-site power.

Reason: This definition has been extracted and slightly modif ied from ICC/RESNET 301 for "on-site pow er production" and is intended to clarify that on-site pow er production can include other pow er than from renew able sources.

Cost Impact: Will not increase the cost of constructionThis proposal only provides a new definition to the IECC Chapter 2 of the Residential Provisions.

Analysis: The term 'on-site pow er production' is not used in the 2015 edition of the IECC. Unless text including use of this term is added by anotherproposal, this term w ill not be included in the 2018 edition of the IECC.


RE8-16 : R202-OPAQUE DOOR (New)-COLLINS11303

RE8-16R202 (New) [IRC N1101.6 (New)]Proponent : David Collins, representing Sustainability, Energy, High Performance Code Action Committee


R202 (IRC N1101.6) OPAQUE DOOR A door that is not less than 50 percent opaque in surface area.

Reason: The term opaque door is used in the residential provisions of the code. A definition is needed to clarify application. The definition proposed isidentical to the IECC Commercial Provisions in Section C202.The IECC defines a door that is more than 50% glass in area as a glass door. Adding this exception to the IECC clarif ies that any door that is not as least50% glazing is considered, for the purposes of the residential provisions of the IECC, an opaque door.

This proposal w as submitted by the ICC Sustainability Energy and High Performance Code Action Committee (SEHPCAC). The SEHPCAC w asestablished by the ICC Board of Directors to pursue opportunities to improve and enhance International Codes w ith regard to sustainability, energy andhigh performance as it relates to the built environment included, but not limited to, how these criteria relate to the International Green Construction Code(IgCC) and the International Energy Conservation Code (IECC). In 2015, the SEHPCAC has held three tw o- or three-day open meetings and 25w orkgroup calls, w hich included members of the SEHPCAC as w ell as any interested parties, to discuss and debate proposed changes and publiccomments. Related documentation and reports are posted on the SEHPCAC w ebsite at: http://w w w .iccsafe.org/cs/SEHPCAC/Pages/default.aspx

Cost Impact: Will not increase the cost of constructionThe proposal clarif ies the code by adding a definition for a term already used in the residential provisions. The action is essentially editorial and shouldhave no cost implications.


http://www.iccsafe.org/cs/SEHPCAC/Pages/default.aspx

RE9-16 : R202-RENEWABLE ENERGY(NEW)-LOVELL13032

RE9-16R202 (New) [IRC N1101.6 (New)]Proponent : Vickie Lovell, InterCode Incorporated, representing Leading Builders of America ([email protected])


R202 (N1101.6) RENEWABLE ENERGY. Energy derived from solar radiation, wind, waves, tides, landfill gas, biomass or theinternal heat of the earth.

Reason: This proposal for a definition of "Renew able Energy" for residential provisions is derived and has been modif ied from the IECC (commercialprovisions) definition in Chapter 2 for "On-site Renew able Energy".

Cost Impact: Will not increase the cost of constructionThe proposal simply adds a definition to IECC-Residential Provisions Chapter 2 and the IRC Chapter 11 (the Energy Chapter). This only serves to clarifythe code and has no impact on the cost of construction.


RE10-16 : R303.4 (NEW)-MOORE11067

RE10-16R303.4 (New) [IRC N1101.13 (New)]Proponent : Mike Moore, Newport Ventures, representing Broan-NuTone, representing Broan-NuTone([email protected])

2015 International Residential CodeAdd new text as follows:

R303.4 (N1101.13) Whole-house mechanical ventilation system airflow testing. Where a whole-house mechanicalventilation system is provided, the airflow shall be tested and verified according to the ventilation equipment manufacturer'sinstructions, or by using a flow hood, flow grid, or other airflow measuring device at the mechanical ventilation fan's inletterminals or grilles, outlet terminals or grilles or in the connected ventilation ducts. A written report of the results of the testshall be signed by the party conducting the test and provided to the code official.

Reason: If not installed correctly, w hole-house mechanical ventilation systems can fail to deliver the minimum outdoor air needed to providedacceptable indoor air quality. A recent study in Florida1 found that only three of 21 w hole house mechanical ventilation systems had a f low rate near thedesign level. Because these systems perform a vital function in supporting building durability and occupant health, these systems should be verif ied forf low w hen installed. This requirement and text are aligned w ith ASHRAE 62.2, Ventilation and Acceptable Indoor Air Quality in Residential Buildings.

Bibliography: 1. Sonne et al. (2015). Investigation of the Effectiveness and Failure Rates of Whole-House Mechanical Ventilation Systems in Florida.FSEC-CR-2002-15. http://w w w .fsec.ucf.edu/en/publications/pdf/FSEC-CR-2002-15.pdf.

Cost Impact: Will increase the cost of constructionTesting the airf low of a w hole house mechanical ventilation system should take about 15-20 minutes. Assuming a skilled labor rate of $50/hr, theincremental cost for the test is estimated at $12-$33. There is no requirement for a third party to conduct the test, w hich can help reduce costs.


RE11-16 : R401.2-FAY12771

RE11-16R401.2 (IRC N1101.13)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


R401.2 Compliance. Projects shall comply with one of the following:

1. Sections R401 through R404.2. Section R405 and the provisions of Sections R401 through R404 labeled "Mandatory."3. An energy rating index (ERI) approach in Section R406 and the provisions of Sections R401 through R404 labeled

"Mandatory."

Reason: This purpose for this code change proposal is to improve and clarify the code language by making it consistent.

Cost Impact: Will not increase the cost of constructionSince code requirements are not proposed to be changed, this proposal w ill not affect the cost of construction.


RE12-16R202 (New) (IRC N1101.6 (New)], R401.2 (IRC N1101.13), R407 (New) [IRC N1107 (New)], R408(New) [IRC N1108 (New)]Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])

2015 International Energy Conservation CodeSECTION 202 (N1101.6) DEFINITIONS

ERI REFERENCE DESIGN. A version of the rated design that meets the minimum requirements of the 2006 InternationalEnergy Conservation Code.

Add new definition as follows:

ECI REFERENCE DESIGNA version of the rated design that meets the minimum requirements of the current International Energy Conservation Code whenexpressed in terms of energy cost.

EUI REFERENCE DESIGNA version of the rated design that meets the minimum requirements of the current International Energy Conservation Code whenexpressed in terms of energy usage.

Revise as follows:

R202 (IRC N1101.6) RATED DESIGN. A description of the proposed building used to determine the energy rating index, energycost index or energy use index..

R401.2 (IRC N1101.13) Compliance. Projects shall comply with one of the following:

1. Sections R401 through R404.2. Section R405 and the provisions of Sections R401 through R404 labeled "Mandatory."3. An energy rating index (ERI) approach in Section R406.4. An energy cost index (ECI) approach in Section 407.5. An energy use index (EUI) approach in Section 408.


SECTION R407 (IRC N1107) ENERGY COST INDEX COMPLIANCE ALTERNATIVE

R407.1(IRC N1107.1) Scope This section establishes criteria for compliance using an Energy Cost Index (ECI) analysis.

R407.2.(IRC N1107.2) Mandatory requirements Compliance with this section requires meeting or exceeding the provisions identified in Sections R401 through R404 labeled asmandatory and the prescriptive provisions of Section R403.5.3. The building thermal envelope efficiency shall be greater than orequal to levels of efficiency and Solar Heat Gain Coefficient in Table R402.1.2 or R402.1.4 of the 2018 International EnergyConservation Code.

Exception: Supply and return ducts not completely inside the building thermal envelope shall be insulated to aminimum of R-6.

R407.3 (IRC N1107.3) Energy cost index The Energy Cost Index (ECI) shall be a numerical integer value that is based on alinear scale constructed such that the ECI reference design has an Index value of 100 and a residential building that has nopurchased energy costs or net energy costs has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the total energy cost of the rated design relative to the total energy cost of the ECI reference design. TheECI shall consider all energy used in the residential building. Energy used to recharge or refuel a vehicle for on-road (and off-site) transportation purposes shall not be included in the ECI reference design or the rated design.

R407.3.1 (IRC N1107.3.1) ECI reference design The ECI reference design shall be configured such that it meets theminimum requirements of the 2018 International Energy Conservation Code prescriptive requirements.

The proposed residential building shall be shown to have an annual total purchased or net energy cost that is less than orequal to the annual purchased or net energy cost of the ERI reference design.

R407.4 (IRC N1107.4) ECI-based compliance Compliance based on an ECI analysis requires that the rated design be shown to have an ECI less than or equal to the ECI ofthe ECI reference design.

R407.5 (IRC N1107,5) Verification by approved agency or entity. Verification of compliance with Section R407 shall be completed by a code official or an approved third party.

R407.6 (IRC N1107.6) Documentation Documentation of the software used to determine the ECI and the parameters for theresidential building shall be in accordance with Sections R407.6.1 through R407.6.3.


R407.6.1 (IRC N1107.6.1) Compliance software tools Documentation verifying that the methods and accuracy of thecompliance software tools conform to the provisions of this section shall be provided to the code official.

R407.6.2 (IRC N1107.6.2) Compliance report Compliance software tools shall generate a report that documents that theECI of the rated design complies with Sections R407.3 and R407.4. The compliance documentation shall include the followinginformation:

1. Address or other form of identification of the residential building or buildings.2. An inspection checklist documenting the building component characteristics of the rated design. The inspection checklistshall show results for both the ECI reference design and the rated design, and shall document all inputs entered by the usernecessary to reproduce the results.3. Name of individual completing the compliance report.4. Name and version of the compliance software tool used.

Exception: Multiple orientations. Where an otherwise identical building model is offered in multiple orientations, compliance forany orientation shall be permitted by documenting that the building meets the performance requirements in each of the four(north, east, south and west) cardinal orientations.

R407.6.3 (IRC N1107.6.3) Additional documentation The code official shall be permitted to require the followingdocuments:

1. Documentation of the building component characteristics of the ECI reference design.2. A certification signed by the builder providing the building component characteristics of the rated design.3. Documentation of the actual values used in the software calculations for the rated design.

R407.7(IRC N1107.7) Calculation software tools Calculation software, where used, shall be in accordance with SectionsR407.7.1 through R407.7.3.

R407.7.1 (IRC N1107.7.1) Minimum capabilities Calculation procedures used to comply with this section shall be softwaretools capable of calculating the ECI as described in Section R407.3, and shall include the following capabilities:

1. Generation of the ECI reference design using only the input for the rated design. The calculation procedure shall not allowthe user to directly modify the building component characteristics of the ECI reference design.2. Calculation of whole building, as a single zone or dual zone, sizing for the heating and cooling equipment in theECI reference design residence in accordance with Section R403.7.3. Calculations that account for the effects of indoor and outdoor temperatures and part-load efficiency and equipmentoperation on the performance of heating, ventilating and air-conditioning equipment based on climate and equipment sizing.4. Printed code official inspection checklist listing each of the rated design component characteristics determined by theanalysis to provide compliance, along with their respective performance ratings.

R407.7.2 (IRC N1107.7.2) Specific approval Performance analysis tools meeting the applicable sections of Section R407shall be approved. Tools are permitted to be approved based on meeting a specified threshold for a jurisdiction. The codeofficial shall approve tools for a specified application or limited scope.

R407.7.3 (IRC 1107.7.3) Input values Where calculations require input values not specified by Sections R402, R403, R404and R405, those input values shall be taken from an approved source.

R408 (IRC N1108). ENERGY USE INDEX COMPLIANCE ALTERNATIVE

R408.1 (IRC N1108.1) Scope This section establishes criteria for compliance using an Energy Use Index (EUI) analysis.

R408.2 (IRC N1108.2) Mandatory requirements Compliance with this section requires meeting or exceeding all of theprovisions identified in Sections R401 through R404 labeled as mandatory and the prescriptive provisions of Section R403.5.3.The building thermal envelope efficiency shall be greater than or equal to levels of efficiency and Solar Heat Gain Coefficient inTable R402.1.2 or R402.1.4 of the 2018 International Energy Conservation Code.

Exception: Supply and return ducts not completely inside the building thermal envelope shall be insulated to a minimum of R-6.

R408.3 (IRC N1108.3) Energy Use Index The Energy Use Index (EUI) shall be a numerical integer value that is based on alinear scale constructed such that the EUI reference design has an Index value of 100 and a residential building that has noannual energy usage or annual net energy usage has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the total energy usage of the rated design relative to the total energy usage of the EUI reference design. TheEUI shall consider all energy used in the residential building. Energy used to recharge or refuel a vehicle for on-road (and off-site) transportation purposes shall not be included in the EUI reference design or the rated design.

R408.3.1 (IRC N1108.3.1) EUI reference design The EUI reference design shall be configured such that it meets theminimum requirements of the 2018 International Energy Conservation Code prescriptive requirements.

The proposed residential building shall be shown to have an annual total or annual net energy usage that is less than or equalto the annual total or annual net energy usage of the EUI reference design.

R408.4 (IRC N1108.4) EUI-based compliance Compliance based on an EUI analysis requires that the rated design beshown to have an EUI less than or equal to the EUI of the EUI reference design.

R408.5 (IRC N1108.5) Verification by approved agency or entity


RE12-16 : R401.2-ROSENSTOCK11920

Verification of compliance with Section R408 shall be completed by a code official or an approved third party.

R408.6 (IRC N1108.6) Documentation Documentation of the software used to determine the EUI and the parameters for theresidential building shall be in accordance with Sections R408.6.1 through R408.6.3.

R408.6.1 (IRC N1108.6.1) Compliance software tools Documentation verifying that the methods and accuracy of thecompliance software tools conform to the provisions of this section shall be provided to the code official.

R408.6.2 (N1108.6.2) Compliance report Compliance software tools shall generate a report that documents that the EUI ofthe rated design complies with Sections R407.3 and R407.4. The compliance documentation shall include the followinginformation:

1. Address or other form of identification of the residential building or buildings.2. An inspection checklist documenting the building component characteristics of the rated design. The inspection checklistshall show results for both the EUI reference design and the rated design, and shall document all inputs entered by the usernecessary to reproduce the results.3. Name of individual completing the compliance report.4. Name and version of the compliance software tool used.

Exception: Multiple orientations. Where an otherwise identical building model is offered in multiple orientations, compliance forany orientation shall be permitted by documenting that the building meets the performance requirements in each of the four(north, east, south and west) cardinal orientations.

R408.6.3 (N1108.6.3) Additional documentation The code official shall be permitted to require the following documents:

1. Documentation of the building component characteristics of the EUI reference design.2. A certification signed by the builder providing the building component characteristics of the rated design.3. Documentation of the actual values used in the software calculations for the rated design.

R408.7 (N1108.7) Calculation software tools Calculation software, where used, shall be in accordance with Sections R408.7.1 through R408.7.3.

R408.7.1 (N1108.7.1) Minimum capabilities Calculation procedures used to comply with this section shall be software toolscapable of calculating the EUI as described in Section R408.3, and shall include the following capabilities:

1. Generation of the EuI reference design using only the input for the rated design. The calculation procedure shall not allowthe user to directly modify the building component characteristics of the EUI reference design.2. Calculation of whole building, as a single zone or dual zone, sizing for the heating and cooling equipment in theEUI reference design residence in accordance with Section R403.7.3. Calculations that account for the effects of indoor and outdoor temperatures and part-load efficiency and equipmentoperation on the performance of heating, ventilating and air-conditioning equipment based on climate and equipment sizing.4. Printed code official inspection checklist listing each of the rated design component characteristics determined by theanalysis to provide compliance, along with their respective performance ratings.

R408.7.2 (N1108.7.2) Specific approval Performance analysis tools meeting the applicable sections of Section R408 shallbe approved. Tools are permitted to be approved based on meeting a specified threshold for a jurisdiction. The code officialshall approve tools for a specified application or limited scope.

R408.7.3 (N1108.7.3) Input values. Where calculations require input values not specified by Sections R402, R403, R404 andR405, those input values shall be taken from an approved source.

Reason: This proposal adds tw o new compliance options to the Residential portion of the IECC. It improves the code in the follow ing w ays:1) It provides more f lexibility to builders and designers. With these tw o new options, builders and designers have more f lexibility in terms of technologyand design choices for residential buildings.

2) These new options use the current IECC as the baseline for comparison, rather than a code that is nearly 10 years old. By using the current IECC asa baseline, there is no need to discuss w hether one previous version of the code, or certain sections of the previous code, are the "correct" baseline. Using previous versions of a code w ill overstate the actual savings and performance of a new residential building relative to a current baseline.

3) These options are modeled w ithout any modif ications that can distort the actual energy usage or energy cost of a residential building.

4) These options are based on metrics that are usable and understandable to consumers. Consumers see actual energy usage and actual energycosts on their monthly electric or natural gas bills.

Cost Impact: Will not increase the cost of constructionThis proposal adds new compliance options that are based on computer simulations, and provide more options to designers and builders. They do notchange any of the requirements in the code and do not increase construction costs.


RE13-16 : R401.2.1-FAY12776

RE13-16R401.2.1 (IRC N1101.13.1)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


R401.2.1 (N1101.13.1) Tropical zone. Residential buildings in the tropical zone at elevations below 2,400 feet (731.5 m) abovesea level shall be deemed to comply with this chapter where the following conditions are met:

1. Not more than one-half of the occupied space is air conditioned.1.1. The cooling load calculated in R403.7 shall not exceed 24,000 Btu/h per 1,000 square feet.

of conditioned space.2. The occupied space is not heated.3. Solar, wind or other renewable energy source supplies not less than 80 percent of the energy for service water

heating.4. Glazing in conditioned occupied space has a solar heat gain coefficient of less than or equal to 0.40, or has an

overhang with a projection factor equal to or greater than 0.30 0.25.5. Permanently installed lighting is in accordance with Section R404.6. The exterior roof surface complies with one of the options in Table C402.3 or the roof/ceiling has insulation with an

R-value of R-15 or greater. If present, attics above the insulation are vented and attics below the insulation areunvented.

7. Roof surfaces have a minimum slope of 1/ 4 inch per foot of run. The finished roof does not have water accumulationareas.

8. Operable fenestration provides ventilation area equal to not less than 14 percent of the floor area in each room.Alternatively, equivalent ventilation is provided by a ventilation fan.

9. Bedrooms with exterior walls facing two different directions have operable fenestration.10. Interior doors to bedrooms are capable of being secured in the open position.11. A ceiling fan or ceiling fan rough-in is provided for bedrooms and the largest space that is not used as a bedroom.

Reason: The purpose of this proposal is to improve the Tropical Zone "deemed to comply" provision f irst established in the 2015 IECC. Specif ically,these improvements are intended to increase the likelihood that the exception created by these provisions w ould still result in reasonably energyeff icient homes. The follow ing are the reasons for the specif ic proposed changes:

The ENERGY STAR Certif ied Homes program requirements for Guam, Haw aii, and Puerto Rico have been customized by US EPA for tropicalclimate zones to include an additional requirement that ensures the design results in a reduced cooling load. This w ould be a reasonableapproach for the IECC as w ell. As a result, w e propose a new requirement (2). The proposed change uses the load calculations requiredunder Section R403.7 to determine w hether the home meets a limit of 24,000 Btu/h per 1,000 sq.ft. This value is a conservative requirement,since it is tw ice the limit permitted for Haw aii in the ENERGY STAR Certif ied Homes program, w hich is designed to ensure that the need formechanical cooling is minimized. The limits for the ENERGY STAR Certif ied Homes program w ere determined through consultation w ith buildersand HVAC contractors along w ith Manual J calculations for homes in tropical regions. It is our understanding that builders have been able tosuccessfully meet the targets set forth in Haw aii and other tropical regions in the three years that the specif ication has been published.Since space conditioning (w indow AC) may be installed after construction, requirement (4) should apply to occupied space, not just conditionedspace.Given the hot/tropical nature of the climate, a low er SHGC, equivalent to the 0.25 SHGC required for climate zones 1-3, is justif ied. We see nojustif ication for a w eaker SHGC under this exception. Since projection factor is not defined in the residential IECC and the relatively low projection factor of 0.30 simply is not suff icient to justifyelimination of the SHGC requirement, w e propose to delete the exception.

There is no explanation of how "equivalent ventilation" from a fan is determined by the code off icial. As a result, this exception should be eliminated.

Cost Impact: Will increase the cost of constructionSince the proposal only modif ies an alternative compliance option, it can only increase the cost of construction if a builder chooses to use this option. The proposed changes may increase the cost of this option. The most likely cost impact w ould be the cost of low ering the SHGC, w hich may increasethe construction cost slightly due to the use of a dif ferent low -e coating. It should be noted, how ever, that there w as no exception and the 0.25 SHGCapplied under the 2012 IECC in this climate zone and w as considered part of a cost-effective set of improvements under US DOE analysis. See U.S.Department of Energy, Cost-Effectiveness Analysis of the Residential Provisions of the 2015 IECC for Hawaii (Oct. 2015).


RE14-16 : R401.3-SCHWARZ12443

RE14-16R401.3 (IRC N1101.14)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R401.3 (N1101.14) Certificate (Mandatory). A permanent certificate shall be completed by the builder or registered designprofessional other approved party and posted on a wall in the space where the furnace is located, a utility room or an approvedlocation inside the building. Where located on an electrical panel, the certificate shall not cover or obstruct the visibility of thecircuit directory label, service disconnect label or other required labels. The certificate shall list the predominant R-values ofinsulation installed in or on ceiling/roof, walls, foundation (slab, basement wall, crawlspace wall and floor) and ducts outsideconditioned spaces; U-factors for fenestration and the solar heat gain coefficient (SHGC) of fenestration, and the results fromany required duct system and building envelope air leakage testing done on the building. Where there is more than one valuefor each component, the certificate shall list the value covering the largest area. The certificate shall list the types andefficiencies of heating, cooling and service water heating equipment. Where a gas-fired unvented room heater, electric furnaceor baseboard electric heater is installed in the residence, the certificate shall list "gas-fired unvented room heater," "electricfurnace" or "baseboard electric heater," as appropriate. An efficiency shall not be listed for gas-fired unvented room heaters,electric furnaces or electric baseboard heaters.

Reason: This could be in the w heelhouse of the design professional, but more often it w ould be the responsibility of the Insulator and or Energy Raterso limiting w ho can generate the certif icate for the Builder does not make sense. As this very important requirement rarely gets executed broadeningw ho can create it is w ell w orth w hile.

Cost Impact: Will not increase the cost of constructionThis proposal w ill not increase cost and in fact is likely to low er cost as design professionals w ould now most likely not be tasked w ith completing thisrequirment of code.


RE15-16 : R401.4.1.2.1 (NEW)-SURRENA12406

RE15-16R402.4.1.2.1 (New)Proponent : Donald Surrena ([email protected])

2015 International Energy Conservation CodeAdd new text as follows:

R402.4.1.2.1 Multi-unit buildings and single family attached building. Multi-unit buildings and single family attachedbuildings shall be tested as a single zone or as individual dwelling units. Common areas shall be treated as isolated test zonesby equalizing pressures to adjacent zones. All conditioned areas of the building shall be tested except where a sampling testprocedure is approved by the code official. A conditioned floor area weighted average air changes per hour for all tested zonesshall be permitted to demonstrate air leakage rate compliance for the building.

Reason: Air tightness testing for single-family detached homes is very straightforw ard, how ever, it is much more diff icult to accurately test attacheddw elling units and multi-family/multi-story buildings. Currently the IECC treats low -rise multifamily buildings of three stories or less like single-familyhomes and multifamily buildings of four stories or more like commercial buildings. Regardless of height, all multifamily buildings have the same air-tightness testing complications to address, such as does the entire building need to be tested at one time, how are the corridors addressed, does everydw elling unit w ithin the multifamily building need to be tested, can the leakages be averaged betw een the dw elling units and is the leakage tested only tothe outside or should it include leakage to adjacent dw elling units. Large multiple dw elling buildings are often tested as isolated test zones due to thenature of the actual testing procedures and available equipment needed to depressurize large volumes of conditioned space and this proposal w ouldrecognize this challenge for those conducting the testing. In addition it also clarif ies that every dw elling need not be required to be tested w hererecognized by the code off icial. By approving this proposal, low -rise multifamily buildings, tw o-unit dw ellings and tow nhouses w ill avoid thesecomplications, but still be held to the same level of performance as high-rise (R-2) residential as w ell as commercial buildings.

Cost Impact: Will not increase the cost of constructionThis proposal offers an optional procedure to building air testing for compliance on typical large-scale projects w hich is not currently available and w illcost less to test.


RE16-16R401.2, R402, R403, R404, R405, R406, R407 (IRC N1101.13, N1102, N1103, N1104, N1105, N1106,N1107)Proponent : Ryan Meres, Institute for Market Transformation, representing Institute for Market Transformation ([email protected])



1. Sections R401 through R404. Section R402 and,2. Section R405 and the provisions of Sections R401 through R403, or R404 labeled "Mandatory , or R405."3. An energy rating index (ERI) approach in Section R406.

Delete and substitute as follows:

SECTION R402 BUILDING THERMAL ENVELOPE MANDATORY REQUIREMENTSNo change to text.

R402.1 General (Prescriptive). The building thermal envelope shall meet the requirements of Sections R402.1.1 throughR402.1.5.

Exception: The following low-energy buildings, or portions thereof, separated from the remainder of the building bybuilding thermal envelope assemblies complying with this section shall be exempt from the building thermal envelopeprovisions of Section R402.

1. Those with a peak design rate of energy usage less than 3.4 Btu/h • ft2 (10.7 W/m2) or 1.0 watt/ft2 of floorarea for space-conditioning purposes.

2. Those that do not contain conditionedspace.

The provisions of Section R402 shall be met regardless of the compliance path chosen.

Revise as follows:

R401.3 R402.2 Certificate (Mandatory). No change to text.


R402.3 Fenestration (Prescriptive) Building thermal envelope. In addition to the requirements of Section R402,fenestration shall comply with Sections R402.3.1 through R402.3.6. The building thermal envelope shall comply with Sections R402.3.1 through R402.3.10.

Revise as follows:

R402.4.1.1 R402.3.1 Installation. The components of the building thermal envelope as listed in Table R402.4.1.1 R402.3.1shall be installed in accordance with the manufacturer's instructions and the criteria listed in Table R402.4.1.1 R402.3.1, asapplicable to the method of construction. Where required by the code official, an approved third party shall inspect allcomponents and verify compliance.

TABLE R402.4.1.1 R402.3.1AIR BARRIER AND INSULATION INSTALLATION

COMPONENT AIR BARRIER CRITERIA INSULATION INSTALLATION CRITERIA

General requirements

A continuous air barrier shall be installed in the building

env elope.The exterior thermal env elope contains a continuous

air barrier.Breaks or joints in the air barrier shall be sealed.

Air-permeable insulation shall not be used as a sealing

material.

Ceiling/attic

The air barrier in any dropped ceiling/sof f it shall be aligned

with the insulation and any gaps in the air barrier shall be

sealed.Access openings, drop down stairs or knee wall doors

to unconditioned attic spaces shall be sealed.

The insulation in any dropped ceiling/sof f it shall be aligned

with the air barrier.

Walls

The junction of the f oundation and sill plate shall be sealed.

The junction of the top plate and the top of exterior walls shall

be sealed.

Knee walls shall be sealed.

Cav ities within corners and headers of f rame walls shall be

insulated by completely f illing the cav ity with a material

hav ing a thermal resistance of R-3 per inch minimum.

Exterior thermal env elope insulation f or f ramed walls shall

be installed in substantial contact and continuous alignment



Windows, sky lights and doorsThe space between window/door jambs and f raming, and

sky lights and f raming shall be sealed.

Rim joists Rim joists shall include the air barrier. Rim joists shall be insulated.

Floors (including abov e garage and

cantilev ered f loors)

The air barrier shall be installed at any exposed edge of

insulation.

Floor f raming cav ity insulation shall be installed to

maintain permanent contact with the underside of subf loor

decking, or f loor f raming cav ity insulation shall be

permitted to be in contact with the top side of sheathing, or

continuous insulation installed on the underside of f loor

f raming and extends f rom the bottom to the top of all

perimeter f loor f raming members.

Crawl space wallsExposed earth in unv ented crawl spaces shall be cov ered with

a Class I v apor retarder with ov erlapping joints taped.

Where prov ided instead of f loor insulation, insulation shall

be permanently attached to the crawlspace walls.

Shaf ts, penetrationsDuct shaf ts, utility penetrations, and f lue shaf ts opening to

exterior or unconditioned space shall be sealed.

Narrow cav ities

Batts in narrow cav ities shall be cut to f it, or narrow

cav ities shall be f illed by insulation that on installation

readily conf orms to the av ailable cav ity space.

Garage separationAir sealing shall be prov ided between the garage and

conditioned spaces.

Recessed lightingRecessed light f ixtures installed in the building thermal

env elope shall be sealed to the dry wall.

Recessed light f ixtures installed in the building thermal

env elope shall be air tight and IC rated.

Plumbing and wiring

Batt insulation shall be cut neatly to f it around wiring and

plumbing in exterior walls, or insulation that on installation

readily conf orms to av ailable space shall extend behind

piping and wiring.

Shower/tub on exterior wallThe air barrier installed at exterior walls adjacent to showers

and tubs shall separate them f rom the showers and tubs.

Exterior walls adjacent to showers and tubs shall be

insulated.

Electrical/phone box on exterior wallsThe air barrier shall be installed behind electrical or

communication boxes or air-sealed boxes shall be installed.

HVAC register bootsHVAC register boots that penetrate building thermal env elope

shall be sealed to the subf loor or dry wall.

Concealed sprinklers

When required to be sealed, concealed f ire sprinklers shall

only be sealed in a manner that is recommended by the

manuf acturer. Caulking or other adhesiv e sealants shall not

be used to f ill v oids between f ire sprinkler cov er plates and

walls or ceilings.

a. In addition, inspection of log walls shall be in accordance with the prov isions of ICC-400.

R402.2.4 R402.3.2 Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such asattics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surroundingsurfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed orequivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to preventthe loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means ofmaintaining the installed R-value of the loose-fill insulation.


Exception: Vertical doors that provide access from conditioned to unconditioned spaces shall be permitted to meet thefenestration requirements of Table R402.1.2 R403.1.1 based on the applicable climate zone specified in Chapter 3.

R402.1.1 R402.3.3 Vapor retarder. No change to text.

R402.4.1.2 R402.3.4 Testing Envelope air leakage testing. The building or dwelling unit shall be tested and verified ashaving an air leakage rate not exceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour inClimate Zones 3 through 8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at apressure of 0.2 inch w.g. (50 Pascals). Where required by the code official, testing shall be conducted by an approved thirdparty. A written report of the results of the test shall be signed by the party conducting the test and provided to the codeofficial. Testing shall be performed at any time after creation of all penetrations of the building thermal envelope.

During testing:

1. Exterior windows and doors, fireplace and stove doors shall be closed, but not sealed, beyond the intendedweatherstripping or other infiltration control measures.

2. Dampers including exhaust, intake, makeup air, backdraft and flue dampers shall be closed, but not sealedbeyond intended infiltration control measures.

3. Interior doors, if installed at the time of the test, shall be open.4. Exterior doors for continuous ventilation systems and heat recovery ventilators shall be closed and sealed.5. Heating and cooling systems, if installed at the time of the test, shall be turned off.6. Supply and return registers, if installed at the time of the test, shall be fully open.

Exceptions:

1. When demonstrating compliance using Section R404 'Simulated Performance Alternative', the envelope airleakage shall be less than or equal to the air changes per hour modelled in the proposed design.

2. When demonstrating compliance using Section R405 'Energy Rating Index Compliance Alternative', the envelopeair leakage shall be less than or equal to the air changes per hour modeled in the rated design.

R402.4.2 R402.3.5 Fireplaces. No change to text.

R402.4.3 R402.3.6 Fenestration air leakage. Windows, skylights and sliding glass doors shall have an air infiltration rate ofno more than 0.3 cfm per square foot (1.5 L/s/m2), and swinging doors no more than 0.5 cfm per square foot (2.6 L/s/m2), whentested according to NFRC 400 or AAMA/WDMA/CSA 101/I.S.2/A440 by an accredited, independent laboratory and listedandlabeledby the manufacturer.

Exception:Site-built windows, skylights and doors.

R402.4.5 R402.3.7 Recessed lighting. No change to text.

R402.4.4 R402.3.8 Rooms containing fuel-burning appliances. In Climate Zones 3 through 8, where open combustion airducts provide combustion air to open combustion fuel burning appliances, the appliances and combustion air opening shall belocated outside the building thermal envelope or enclosed in a room, isolated from inside the thermal envelope. Such roomsshall be sealed and insulated in accordance with the envelope requirements of Table R402.1.2 R403.1.1, where the walls, floorsand ceilings shall meet not less than the basement wall R-value requirement. The door into the room shall be fully gasketedand any water lines and ducts in the room insulated in accordance with Section R403 R403.4. The combustion air duct shall beinsulated where it passes through conditioned space to a minimum of R-8.

Exceptions:1. Direct vent appliances with both intake and exhaust pipes installed continuous to the outside.2. Fireplaces and stoves complying with Section R402.4.2 R402.3.5 and Section R1006 of the International

Residential Code.

R402.2.3 R402.3.9 Eave baffle. No change to text.

R402.5 R402.3.10 Maximum fenestration U-factor and SHGC (Mandatory). The area-weighted average maximumfenestration U-factor permitted using tradeoffs from Section R402.1.5 R403.1.2 or R405 R404 shall be 0.48 in Climate Zones 4and 5 and 0.40 in Climate Zones 6 through 8 for vertical fenestration, and 0.75 in Climate Zones 4 through 8 for skylights. Thearea-weighted average maximum fenestration SHGC permitted using tradeoffs from Section R405 in Climate Zones 1 through 3shall be 0.50.


R402.4 Air leakage (Mandatory) Systems. The building thermal envelope shall be constructed to limit air leakage inaccordance with the requirements of Sections R402.4.1 through R402.4.5. All systems shall comply with Sections R402.4.1 through R402.5.2.

Delete without substitution:

R402.4.1 Building thermal envelope. The building thermal envelope shall comply with Sections R402.4.1.1 andR402.4.1.2. The sealing methods between dissimilar materials shall allow for differential expansion and contraction.

Revise as follows:


R403.1 R402.4.1 Controls (Mandatory). No change to text.

R403.1.1 R402.4.1.1 Programmable thermostat. No change to text.

R403.1.2 R402.4.1.2 Heat pump supplementary heat (Mandatory). No change to text.

R403.2 R402.4.1.3 Hot water boiler outdoor temperature setback. No change to text.

R403.3 R402.4.2 Ducts. Ducts and air handlers shall be in accordance with Sections R403.3.1 R402.4.2.1 through R403.3.5 R402.4.2.6.

R403.3.2 R402.4.2.1 Sealing (Mandatory). Ducts, air handlers and filter boxes shall be sealed. Joints and seams shallcomply with either the International Mechanical Code or International Residential Code, as applicable.

Exceptions:1. Air-impermeable spray foam products shall be permitted to be applied without additional joint seals.2. For ducts having a static pressure classification of less than 2 inches of water column (500 Pa), additional

closure systems shall not be required for continuously welded joints and seams, and locking-type joints andseams of other than the snap-lock and button-lock types.

R403.3.2.1 R402.4.2.2 Sealed air handler. No change to text.

R403.3.3 R402.4.2.3 Duct testing (Mandatory). Ducts shall be pressure tested to determine air leakage by one of thefollowing methods:

1. Rough-in test: Total leakage shall be measured with a pressure differential of 0.1 inch w.g. (25 Pa) across thesystem, including the manufacturer's air handler enclosure if installed at the time of the test. All registers shall betaped or otherwise sealed during the test.

2. Postconstruction test: Total leakage shall be measured with a pressure differential of 0.1 inch w.g. (25 Pa) acrossthe entire system, including the manufacturer's air handler enclosure. Registers shall be taped or otherwise sealedduring the test.

Exception:A duct air leakage test shall not be required where the ducts and air handlers are located entirelywithin the building thermal envelope.

A written report of the results of the test shall be signed by the party conducting the test and provided to the code official.

R403.3.4 R402.4.2.4 Duct leakage (Prescriptive). The total leakage of the ducts, where measured in accordance withSection R403.3.3 R402.4.2.3, shall be as follows:

1. Rough-in test: The total leakage shall be less than or equal to 4 cubic feet per minute (113.3 L/min) per 100 squarefeet (9.29 m2) of conditioned floor area where the air handler is installed at the time of the test. Where the airhandler is not installed at the time of the test, the total leakage shall be less than or equal to 3 cubic feet perminute (85 L/min) per 100 square feet (9.29 m2) of conditioned floor area.

2. Postconstruction test: Total leakage shall be less than or equal to 4 cubic feet per minute (113.3 L/min) per 100square feet (9.29 m2) of conditioned floor area.

Exceptions:

1. When demonstrating compliance using Section R404 'Simulated Performance Alternative', the duct leakage shallbe less than or equal to the duct leakage modelled in the proposed design.

2. When demonstrating compliance using Section R405 'Energy Rating Index Compliance Alternative', the ductleakage shall be less than or equal to the duct leakage modelled in the rated design.

R403.3.1 R402.4.2.5 Insulation (Prescriptive) Duct insulation. Supply and return ducts in attics shall be insulated to aminimum of R-8 where 3 inches (76 mm) in diameter and greater and R-6 where less than 3 inches (76 mm) in diameter.Supply and return ducts in other portions of the building shall be insulated to a minimum of R-6 where 3 inches (76 mm) indiameter or greater and R-4.2 where less than 3 inches (76 mm) in diameter.

Exception:Ducts or portions thereof located completely inside the building thermal envelope.

R403.3.5 R402.4.2.6 Building cavities (Mandatory). No change to text.

R403.4 R402.4.3 Mechanical system piping insulation (Mandatory). No change to text.

R403.4.1 R402.4.3.1 Protection of piping insulation. No change to text.

R403.5 R402.4.4 Service hot water systems. Energy conservation measures for service hot water systems shall be inaccordance with Sections R403.5.1 R402.4.4.1 through R403.5.4 R402.4.4.4.

R403.5.1 R402.4.4.1 Heated water circulation and temperature maintenance systems (Mandatory). Heated watercirculation systems shall be in accordance with Section R403.5.1.1 R402.4.4.1.1. Heat trace temperature maintenancesystems shall be in accordance with Section R403.5.1.2 R402.4.4.1.2. Automatic controls, temperature sensors and pumpsshall be accessible. Manual controls shall be readily accessible.


R403.5.1.1 R402.4.4.1.1 Circulation systems. No change to text.

R403.5.1.2 R402.4.4.1.2 Heat trace systems. No change to text.

R403.5.2 R402.4.4.2 Demand recirculation systems. A water distribution system having one or more recirculation pumpsthat pump water from a heated water supply pipe back to the heated water source through a cold water supply pipe shall be ademand recirculation water system. Pumps shall have controls that comply with both of the following:

1. The control shall start the pump upon receiving a signal from the action of a user of a fixture or appliance, sensingthe presence of a user of a fixture or sensing the flow of hot or tempered water to a fixture fitting or appliance.

2. The control shall limit the temperature of the water entering the cold water piping to 104ºF (40ºC).

R403.5.3 R402.4.4.3 Hot water pipe insulation (Prescriptive). Insulation for hot water pipe with a minimum thermalresistance (R-value) of R-3 shall be applied to the following:

1. Piping 3/ 4 inch (19.1 mm) and larger in nominal diameter.2. Piping serving more than one dwelling unit.3. Piping located outside the conditioned space.4. Piping from the water heater to a distribution manifold.5. Piping located under a floor slab.6. Buried in piping.7. Supply and return piping in recirculation systems other than demand recirculation systems.

R403.5.4 R402.4.4.4 Drain water heat recovery units. No change to text.

R403.6 R402.4.5 Mechanical ventilation (Mandatory). No change to text.

R403.6.1 R402.4.5.1 Whole-house mechanical ventilation system fan efficacy. Mechanical ventilation system fans shallmeet the efficacy requirements of Table R403.6.1 R402.4.5.1.

Exception: Where mechanical ventilation fans are integral to tested and listed HVAC equipment, they shall be poweredby an electronically commutated motor.

TABLE R403.6.1 R402.4.5.1MECHANICAL VENTILATION SYSTEM FAN EFFICACY

FAN LOCATIONAIR FLOW RATE MINIMUM

(CFM)

MINIMUM EFFICACY

(CFM/WATT)

AIR FLOW RATE MAXIMUM

(CFM)

Range hoods Any 2.8 cf m/watt Any

In-line f an Any 2.8 cf m/watt Any

Bathroom, utility room 10 1.4 cf m/watt

Bathroom, utility room 90 2.8 cf m/watt Any

For SI: 1 cf m = 28.3 L/min.

R403.7 R402.4.6 Equipment sizing and efficiency rating (Mandatory). No change to text.

R403.8 R402.4.7 Systems serving multiple dwelling units (Mandatory). Systems serving multiple dwelling units shallcomply with Sections C403 and C404 of the IECC—Commercial Provisions in lieu of Section R403 R402.4.

R403.9 R402.4.8 Snow melt and ice system controls (Mandatory). No change to text.

R403.10 R402.4.9 Pools and permanent spa energy consumption (Mandatory). The energy consumption of pools andpermanent spas shall be in accordance with Sections R403.10.1 R402.9.1 through R403.10.3 R402.9.4.

R403.12 R402.4.9.1 Residential pools and permanent residential spas. No change to text.

R403.10.1 R402.4.9.2 Heaters. No change to text.

R403.10.2 R402.4.9.3 Time switches. Time switches or other control methods that can automatically turn off and onaccording to a preset schedule shall be installed for heaters and pump motors. Heaters and pump motors that have built-intime switches shall be in compliance with this section.

Exceptions:1. Where public health standards require 24-hour pump operation.2. Pumps that operate solar- and waste-heat-recovery pool heating systems.

R403.10.3 R402.4.9.4 Covers. Outdoor heated pools and outdoor permanent spas shall be provided with a vapor-retardantcover or other approved vapor-retardant means.


Exception: Where more than 70 percent of the energy for heating, computed over an operation season, is from site-recovered energy, such as from a heat pump or solar energy source, covers or other vapor-retardant means shall not berequired.

R403.11 R402.4.10 Portable spas (Mandatory). No change to text.

R404 R402.5 ELECTRICAL POWER AND LIGHTING SYSTEMS Electrical power and lighting systems.

R404.1 R402.5.1 Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lightingfixtures shall be high-efficacy lamps or not less than 75 percent of the permanently installed lighting fixtures shall contain onlyhigh-efficacy lamps.

Exception: Low-voltage lighting.

R404.1.1 R402.5.2 Lighting Fuel gas lighting equipment (Mandatory). No change to text.


SECTION R403 SYSTEMS Prescriptive Compliance PathNo change to text.

Revise as follows:

R403.1 General. The building thermal envelope shall meet the requirements of Sections R403.1.1 through R403.3.5.

Exception: The following low-energy buildings, or portions thereof, separated from the remainder of the building bybuilding thermal envelope assemblies complying with this section shall be exempt from the building thermalenvelope provisions of Section R403.


2. Those that do not contain conditionedspace.

R402.1.2 R403.1.1 Insulation and fenestration criteria. The building thermal envelopeshall meet the requirements of TableR402.1.2 R403.1.1, based on the climate zone specified in Chapter 3.

TABLE R402.1.2 R403.1.1INSULATION AND FENESTRATION REQUIREMENTS BY COMPONENTa

CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5 h 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19

For SI: 1 f oot = 304.8 mm.

a. R-v alues are minimums. U -f actors and SHGC are maximums. When insulation is installed in a cav ity which is less than the label or design thickness of the insulation,the installed R -v alue of the insulation shall not be less than the R -v alue specif ied in the table.

b. The f enestration U -f actor column excludes sky lights. The SHGC column applies to all glazed f enestration. Exception: Sky lights may be excluded f rom glazedf enestration SHGC requirements in climate zones 1 through 3 where the SHGC f or such sky lights does not exceed 0.30.

c. "15/19" means R-15 continuous insulation on the interior or exterior of the home or R-19 cav ity insulation at the interior of the basement wall. "15/19" shall be permittedto be met with R-13 cav ity insulation on the interior of the basement wall plus R-5 continuous insulation on the interior or exterior of the home. "10/13" means R-10continuous insulation on the interior or exterior of the home or R-13 cav ity insulation at the interior of the basement wall.

d. R-5 shall be added to the required slab edge R -v alues f or heated slabs. Insulation depth shall be the depth of the f ooting or 2 f eet, whichev er is less in Climate Zones 1through 3 f or heated slabs.

e. There are no SHGC requirements in the Marine Zone.

f . Basement wall insulation is not required in warm-humid locations as def ined by Figure R301.1 and Table R301.1.

g. Or insulation suf f icient to f ill the f raming cav ity , R-19 minimum.

h. The f irst v alue is cav ity insulation, the second v alue is continuous insulation, so "13+5" means R-13 cav ity insulation plus R-5 continuous insulation.

i. The second R -v alue applies when more than half the insulation is on the interior of the mass wall.

R402.1.3 R403.1.2 R-value computation. Insulation material used in layers, such as framing cavity insulation, or continuousinsulation shall be summed to compute the corresponding component R-value. The manufacturer's settled R-value shall be


used for blown insulation. Computed R-values shall not include an R-value for other building materials or air films. Whereinsulated siding is used for the purpose of complying with the continuous insulation requirements of Table R402.1.2 R403.1.1,the manufacturer's labeled R-value for insulated siding shall be reduced by R-0.6.

R402.1.4 R403.1.3 U-factor alternative. An assembly with a U-factor equal to or less than that specified in Table R402.1.4 R403.1.4 shall be permitted as an alternative to the R-value in Table R402.1.2 R403.1.1.

R402.1.5 R403.1.4 Total UA alternative. If the total building thermal envelopeUA (sum of U-factor times assembly area) isless than or equal to the total UA resulting from using the U-factors in Table R402.1.4 R403.1.4 (multiplied by the sameassembly area as in the proposed building), the building shall be considered in compliance with Table R402.1.2 R403.1.1. TheUA calculation shall be done using a method consistent with the ASHRAE Handbook of Fundamentalsand shall include thethermal bridging effects of framing materials. The SHGC requirements shall be met in addition to UA compliance.

TABLE R402.1.4 R403.1.4EQUIVALENT U-FACTORSa

CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055

a. Nonf enestration U- f actors shall be obtained f rom measurement, calculation or an approv ed source.

b. When more than half the insulation is on the interior, the mass wall U-f actors shall be a maximum of 0.17 in Climate Zone 1, 0.14 in Climate Zone 2, 0.12 in ClimateZone 3, 0.087 in Climate Zone 4 except Marine, 0.065 in Climate Zone 5 and Marine 4, and 0.057 in Climate Zones 6 through 8.

c. Basement wall U- f actor of 0.360 in warm-humid locations as def ined by Figure R301.1 and Table R301.1.

R402.2 R403.2 Specific insulation requirements (Prescriptive). In addition to the requirements of Section R402.1 R403.2.1,insulation shall meet the specific requirements of Sections R402.2.1 R403.2.1 through R402.2.13 R403.2.11.

R402.2.1 R403.2.1 Ceilings with attic spaces. Where Section R402.1.2 R403.1.1 would require R-38 insulation in the ceiling,installing R-30 over 100 percent of the ceiling area requiring insulation shall be deemed to satisfy the requirement for R-38wherever the full height of uncompressed R-30 insulation extends over the wall top plate at the eaves. Similarly, where SectionR402.1.2 R403.1.1 would require R-49 insulation in the ceiling, installing R-38 over 100 percent of the ceiling area requiringinsulation shall be deemed to satisfy the requirement for R-49 insulation wherever the full height of uncompressed R-38insulation extends over the wall top plate at the eaves. This reduction shall not apply to the U-factor alternative approach inSection R402.1.4 R403.1.3 and the total UA alternative in Section R402.1.5 R403.1.4.

R402.2.2 R403.2.2 Ceilings without attic spaces. Where Section R402.1.2 R403.1.1 would require insulation levels above R-30 and the design of the roof/ceiling assembly does not allow sufficient space for the required insulation, the minimum requiredinsulation for such roof/ceiling assemblies shall be R-30. This reduction of insulation from the requirements of Section R402.1.2 R403.1.1 shall be limited to 500 square feet (46 m2) or 20 percent of the total insulated ceiling area, whichever is less. Thisreduction shall not apply to the U-factor alternative approach in Section R402.1.4 R403.1.3 and the total UA alternative inSection R402.1.5 R403.1.4.

R402.2.5 R403.2.3 Mass walls. No change to text.

R402.2.6 R403.2.4 Steel-frame ceilings, walls and floors. Steel-frame ceilings, walls, and floors shall meet the insulationrequirements of Table R402.2.6 R403.2.4 or shall meet the U-factor requirements of Table R402.1.4 R403.1.3. The calculationof the U-factor for a steel-frame envelope assembly shall use a series-parallel path calculation method.

TABLE R402.2.6 R403.2.4STEEL-FRAME CEILING, WALL AND FLOOR INSULATION (R-VALUE)

WOOD FRAME

R-VALUE

REQUIREMENT

COLD-FORMED STEEL

EQUIVALENT R-VALUEa

Steel Truss Ceilingsb

R-30 R-38 or R-30 + 3 or R-26 + 5

R-38 R-49 or R-38 + 3


R-49 R-38 + 5

Steel Joist Ceilingsb

R-30 R-38 in 2 × 4 or 2 × 6 or 2 × 8 R-49 in any f raming

R-38 R-49 in 2 × 4 or 2 × 6 or 2 × 8 or 2 × 10

Steel-Framed Wall, 16″ on center

R-13 R-13 + 4.2 or R-19 + 2.1 or R-21 + 2.8 or R-0 + 9.3 or R-15 + 3.8 or R-21 + 3.1

R-13 + 3 R-0 + 11.2 or R-13 + 6.1 or R-15 + 5.7 or R-19 + 5.0 or R-21 + 4.7


R-20 + 5 R-13 + 12.7 or R-15 + 12.3 or R-19 + 11.6 or R-21 + 11.3 or R-25 + 10.9


Steel Framed Wall, 24″ on center

R-13 R-0 + 9.3 or R-13 + 3.0 or R-15 + 2.4

R-13 + 3 R-0 + 11.2 or R-13 + 4.9 or R-15 + 4.3 or R-19 + 3.5 or R-21 + 3.1

R-20 R-0 + 14.0 or R-13 + 7.7 or R-15 + 7.1 or R-19 + 6.3 or R-21 + 5.9

R-20 + 5 R-13 + 11.5 or R-15 + 10.9 or R-19 + 10.1 or R-21 + 9.7 or R-25 + 9.1


Steel Joist Floor

R-13 R-19 in 2 × 6, or R-19 + 6 in 2 × 8 or 2 × 10

R-19 R-19 + 6 in 2 × 6, or R-19 + 12 in 2 × 8 or 2 × 10

a Cav ity insulation R- v alue is listed f irst, f ollowed by continuous insulation R- v alue.

b. Insulation exceeding the height of the f raming shall cov er the f raming.

R402.2.7 R403.2.5 Walls with partial structural sheathing. Where Section R402.1.2 R403.1.1 would require continuousinsulation on exterior walls and structural sheathing covers 40 percent or less of the gross area of all exterior walls, thecontinuous insulation R-value shall be permitted to be reduced by an amount necessary to result in a consistent totalsheathing thickness, but not more than R-3, on areas of the walls covered by structural sheathing. This reduction shall notapply to the U-factor alternative approach in Section R402.1.4 R403.1.3 and the total UA alternative in Section R402.1.5 R403.1.4.

R402.2.8 R403.2.6 Floors. Floor framing-cavity insulation shall be installed to maintain permanent contact with the undersideof the subfloor decking.

Exception: The floor framing-cavity insulation shall be permitted to be in contact with the topside of sheathing orcontinuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceedsthe minimum wood frame wall R-value in Table 402.1.2 403.1.1 and that extends from the bottom to the top of allperimeter floor framing members.

R402.2.9 R403.2.7 Basement walls. Walls associated with conditioned basements shall be insulated from the top of thebasement walldown to 10 feet (3048 mm) below grade or to the basement floor, whichever is less. Walls associated withunconditioned basements shall meet this requirement unless the floor overhead is insulated in accordance with SectionsR402.1.2 R403.1.1 and R402.2.8 R403.2.6.

R402.2.10 R403.2.8 Slab-on-grade floors. Slab-on-grade floors with a floor surface less than 12 inches (305 mm) below gradeshall be insulated in accordance with Table R402.1.2 R403.1.1. The insulation shall extend downward from the top of the slab


on the outside or inside of the foundation wall. Insulation located below grade shall be extended the distance provided in TableR402.1.2 R403.1.1 by any combination of vertical insulation, insulation extending under the slab or insulation extending outfrom the building. Insulation extending away from the building shall be protected by pavement or by not less than 10 inches(254 mm) of soil. The top edge of the insulation installed between the exterior walland the edge of the interior slab shall bepermitted to be cut at a 45-degree (0.79 rad) angle away from the exterior wall.Slab-edge insulation is not required injurisdictions designated by the code officialas having a very heavy termite infestation.

R402.2.11 R403.2.9 Crawl space walls. No change to text.

R402.2.12 R403.2.10 Masonry veneer. No change to text.

R402.2.13 R403.2.11 Sunroom insulation. Sunrooms enclosing conditioned space shall meet the insulation requirements ofthis code.

Exception: For sunrooms with thermal isolation, and enclosing conditioned space, the following exceptions to theinsulation requirements of this code shall apply:

1. The minimum ceiling insulation R-values shall be R-19 in Climate Zones 1 through 4 and R-24 in ClimateZones 5 through 8.

2. The minimum wall R-value shall be R-13 in all climate zones. Walls separating a sunroom with a thermalisolation from conditioned space shall meet the building thermal envelope requirements of this code.

R403.3 Fenestration. In addition to the requirements of Section R403, fenestration shall comply with Sections R403.3.1through R403.3.6.

R402.3.1 R403.3.1 U-factor. No change to text.

R402.3.2 R403.3.2 Glazed fenestration SHGC. An area-weighted average of fenestration products more than 50-percentglazed shall be permitted to satisfy the SHGC requirements.

Dynamic glazing shall be permitted to satisfy the SHGC requirements of Table R402.1.2 provided the ratio of the higher tolower labeled SHGC is greater than or equal to 2.4, and the dynamic glazing is automatically controlled to modulate theamount of solar gain into the space in multiple steps. Dynamic glazing shall be considered separately from other fenestration,and area-weighted averaging with other fenestration that is not dynamic glazing shall not be permitted.

Exception:Dynamic glazing is not required to comply with this section when both the lower and higher labeled SHGCalready comply with the requirements of Table R402.1.2 R403.1.1.

R402.3.3 R403.3.3 Glazed fenestration exemption. Up to 15 square feet (1.4 m2) of glazed fenestration per dwelling unitshall be permitted to be exempt from U-factor and SHGC requirements in Section R402.1.2 R403.1.1. This exemption shall notapply to the U-factor alternative approach in Section R402.1.4 R403.1.3 and the Total UA alternative in Section R402.1.5 R403.1.4.

R402.3.4 R403.3.4 Opaque door exemption. One side-hinged opaque door assembly up to 24 square feet (2.22 m2) in areais exempted from the U-factor requirement in Section R402.1.4 R403.1.3. This exemption shall not apply to the U-factoralternative approach in Section R402.1.4 R403.1.3 and the total UA alternative in Section R402.1.5 R403.1.4.

R402.3.5 R403.3.5 Sunroom fenestration. Sunrooms enclosing conditioned space shall meet the fenestration requirementsof this code.

Exception: For sunrooms with thermal isolation and enclosing conditioned space in Climate Zones 2 through 8, themaximum fenestration U-factor shall be 0.45 and the maximum skylight U-factor shall be 0.70.

New fenestration separating the sunroom with thermal isolation from conditionedspace shall meet the building thermalenvelope requirements of this code.

R405 R404 R405 R404 SIMULATED PERFORMANCE ALTERNATIVE (PERFORMANCE)

R405.1 R404.1 Scope. No change to text.

R405.2 R404.2 Mandatory requirements. Compliance with this section requires that the mandatory provisions identified inSection R401.2 R402 be met. All supply and return ducts not completely inside the building thermal envelope shall beinsulated to a minimum of R-6.

R405.3 R404.3 Performance-based compliance. Compliance based on simulated energy performance requires that aproposed residence (proposed design)be shown to have an annual energy cost that is less than or equal to the annual energycost of the standard reference design.Energy prices shall be taken from a source approvedby the code official,such as theDepartment of Energy, Energy Information Administration's State Energy Price and Expenditure Report. Code officialsshall bepermitted to require time-of-use pricing in energy cost calculations.

Exception:The energy use based on source energy expressed in Btu or Btu per square foot of conditioned floorareashall be permitted to be substituted for the energy cost. The source energy multiplier for electricity shall be 3.16.The source energy multiplier for fuels other than electricity shall be 1.1.

R405.4 R404.4 Documentation. Documentation of the software used for the performance design and the parameters for thebuilding shall be in accordance with Sections R405.4.1 R404.4.1 through R405.4.3 R404.4.3.

R405.4.1 R404.4.1 Compliance software tools. No change to text.


R405.4.2 R404.4.2 Compliance report. Compliance software tools shall generate a report that documents that the proposeddesign complies with Section R405.3 R404.3. A compliance report on the proposed design shall be submitted with theapplication for the building permit. Upon completion of the building, a compliance report based on the as-built condition of thebuilding shall be submitted to the code official before a certificate of occupancy is issued. Batch sampling of buildings todetermine energy code compliance for all buildings in the batch shall be prohibited.

Compliance reports shall include information in accordance with Sections R405.4.2.1 R404.4.2.1 and R405.4.2.2 R404.4.2.2. Where the proposed design of a building could be built on different sites where the cardinal orientation of thebuilding on each site is different, compliance of the proposed design for the purposes of the application for the building permitshall be based on the worst-case orientation, worst-case configuration, worst-case building air leakage and worst- case ductleakage. Such worst-case parameters shall be used as inputs to the compliance software for energy analysis.

R405.4.2.1 R404.4.2.1 Compliance report for permit application. A compliance report submitted with the application forbuilding permit shall include the following:

1. Building street address, or other building site identification.2. A statement indicating that the proposed designcomplies with Section R405.3 R404.3.3. An inspection checklist documenting the building component characteristics of the proposed design as indicated in

Table R405.5.2(1 R404.5.2(1). The inspection checklist shall show results for both the standard reference designand the proposed design with user inputs to the compliance software to generate the results.

4. A site-specific energy analysis report that is in compliance with Section R405.3 R404.3.5. The name of the individual performing the analysis and generating the report.6. The name and version of the compliance software tool.

R405.4.2.2 R404.4.2.2 Compliance report for certificate of occupancy. A compliance report submitted for obtaining thecertificate of occupancy shall include the following:

1. Building street address, or other building site identification.2. A statement indicating that the as-built building complies with Section R405.3 R404.3.3. A certificate indicating that the building passes the performance matrix for code compliance and listing the energy

saving features of the buildings.4. A site-specific energy analysis report that is in compliance with Section R405.3 R404.3.5. The name of the individual performing the analysis and generating the report.6. The name and version of the compliance software tool.

R405.4.3 R404.4.3 Additional documentation. The code officialshall be permitted to require the following documents:

1. Documentation of the building component characteristics of the standard reference design.2. A certification signed by the builder providing the building component characteristics of the proposed designas

given in Table R405.5.2(1 R404.5.2(1).3. Documentation of the actual values used in the software calculations for the proposed design.

R405.5 R404.5 Calculation procedure. Calculations of the performance design shall be in accordance with SectionsR405.5.1 R404.5.1 and R405.5.2 R404.5.2.

R405.5.1 R404.5.1 General. No change to text.

R405.5.2 R404.5.2 Residence specifications. The standard reference designand proposed designshall be configured andanalyzed as specified by Table R405.5.2(1 R404.5.2(1). Table R405.5.2(1 R404.5.2(1) shall include, by reference, all notescontained in Table R402.1.2 R403.1.1.

TABLE R405.5.2 R404.5.2 (2) DEFAULT DISTRIBUTION SYSTEM EFFICIENCIES FOR PROPOSED DESIGNSa

DISTRIBUTION SYSTEM CONFIGURATION AND CONDITION FORCED AIR SYSTEMS HYDRONIC SYSTEMS b

Distribution sy stem components located in unconditioned space — 0.95

Untested distribution sy stems entirely located in conditioned space c 0.88 1

"Ductless" sy stems d 1 —

For SI: 1 cubic f oot per minute = 0.47 L/s, 1 square f oot = 0.093 m 2 , 1 pound per square inch = 6895 Pa, 1 inch water gauge = 1250 Pa.

a. Def ault v alues giv en by this table are f or untested distribution sy stems, which must still meet minimum requirements f or duct sy stem insulation.

b. Hy dronic sy stems shall mean those sy stems that distribute heating and cooling energy directly to indiv idual spaces using liquids pumped through closed-loop piping andthat do not depend on ducted, f orced airf low to maintain space temperatures.

c. Entire sy stem in conditioned space shall mean that no component of the distribution sy stem, including the air-handler unit, is located outside of the conditioned space.

d. Ductless sy stems shall be allowed to hav e f orced airf low across a coil but shall not hav e any ducted airf low external to the manuf acturer's air-handler enclosure.

TABLE R405.5.2 R404.5.2 (1) SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS


BUILDING COMPONENT STANDARD REFERENCE DESIGN PROPOSED DESIGN

Mechanical v entilation

None, except where mechanical v entilation is specif ied by the

proposed design, in which case:Annual v ent f an energy

use:kWh/y r = 0.03942 × CFA + 29.565 × (Nbr +1)where:CFA =

conditioned f loor areaNbr = number of bedrooms

As proposed

Internal gainsIGain = 17,900 + 23.8 × CFA + 4104 × Nbr (Btu/day per dwelling

unit)Same as standard ref erence design.

Internal massAn internal mass f or f urniture and contents of 8 pounds per square

f oot of f loor area.

Same as standard ref erence design, plus any additional mass

specif ically designed as a thermal storage elementc but not

integral to the building env elope or structure.

Structural mass For masonry f loor slabs, 80 percent of f loor area cov ered by R-2

carpet and pad, and 20 percent of f loor directly exposed to room

air.

As proposed

For masonry basement walls, as proposed, but with insulation

required by Table R4023.1.4 located on the interior side of the

walls

As proposed

For other walls, f or ceilings, f loors, and interior walls, wood f rame

construction

As proposed

Heating sy stemsd, e

As proposed f or other than electric heating without a heat pump,

where the proposed design utilizes electric heating without a heat

pump the standard ref erence design shall be an air source heat

pump meeting the requirements of Section C403 of the IECC-

Commercial Prov isions.Capacity : sized in accordance with Section

R402.4.63.7

As proposed

Cooling sy stemsd, fAs proposed Capacity : sized in accordance with Section

R402.4.63.7.As proposed

Serv ice water heatingd, e, f , gAs proposed

Use: same as proposed design

As proposed

gal/day = 30 + (10 × Nbr )

Thermal distribution sy stems Duct insulation: From Section R402.4.2.53.2.1 A thermal

distribution sy stem ef f iciency (DSE) of 0.88 shall be applied to

both the heating and cooling sy stem ef f iciencies f or all sy stems

other than tested duct sy stems. For tested duct sy stems, the

leakage rate shall be 4 cf m (113.3 L/min) per 100 f t2 (9.29 m2 ) of

conditionedfloor area at a pressure of dif f erential of 0.1 inches

w.g. (25 Pa).

As tested or as specif ied in Table R4054.5.2(2) if not tested.

Duct insulation shall be as proposed.

ThermostatTy pe: Manual, cooling temperature setpoint = 75°F; Heating

temperature setpoint = 72°FSame as standard ref erence

For SI: 1 square f oot = 0.93 m 2 , 1 British thermal unit = 1055 J, 1 pound per square f oot = 4.88 kg/m 2 , 1 gallon (US) = 3.785 L, Â°C = (Â°F-32)/1.8, 1 degree = 0.79 rad.

a. Where required by the code official , testing shall be conducted by an approved party . Hourly calculations as specif ied in the ASHRAE Handbook of Fundamentals , or theequiv alent shall be used to determine the energy loads resulting f rom inf iltration.

b. The combined air exchange rate f or inf iltration and mechanical v entilation shall be determined in accordance with Equation 43 of 2001 ASHRAE Handbook of Fundamentals, page 26.24 and the "Whole-house Ventilation" prov isions of 2001 ASHRAE Handbook of Fundamentals , page 26.19 f or intermittent mechanical v entilation.

c. Thermal storage element shall mean a component not part of the f loors, walls or ceilings that is part of a passiv e solar sy stem, and that prov ides thermal storage such asenclosed water columns, rock beds, or phase-change containers. A thermal storage element must be in the same room as f enestration that f aces within 15 degrees (0.26 rad)of true south, or must be connected to such a room with pipes or ducts that allow the element to be activ ely charged.


d. For a proposed design with multiple heating, cooling or water heating sy stems using dif f erent f uel ty pes, the applicable standard ref erence design sy stem capacities andf uel ty pes shall be weighted in accordance with their respectiv e loads as calculated by accepted engineering practice f or each equipment and f uel ty pe present.

e. For a proposed design without a proposed heating sy stem, a heating sy stem with the prev ailing f ederal minimum ef f iciency shall be assumed f or both the standardref erence design and proposed design.

f . For a proposed design home without a proposed cooling sy stem, an electric air conditioner with the prev ailing f ederal minimum ef f iciency shall be assumed f or both thestandard ref erence design and the proposed design.

g. For a proposed design with a nonstorage-ty pe water heater, a 40-gallon storage-ty pe water heater with the prev ailing f ederal minimum energy f actor f or the same f uel asthe predominant heating f uel ty pe shall be assumed. For the case of a proposed design without a proposed water heater, a 40-gallon storage-ty pe water heater with theprev ailing f ederal minimum ef f iciency f or the same f uel as the predominant heating f uel ty pe shall be assumed f or both the proposed design and standard ref erence design.

h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area. As = Standard ref erence design total glazing area. FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions. Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit. L and CFA are in the same units.

R405.6 R404.6 Calculation software tools. Calculation software, where used, shall be in accordance with Sections R405.6.1 R404.6.1 through R405.6.3 R404.6.3.

R405.6.1 R404.6.1 Minimum capabilities. Calculation procedures used to comply with this section shall be software toolscapable of calculating the annual energy consumption of all building elements that differ between the standard referencedesignand the proposed designand shall include the following capabilities:

1. Computer generation of the standard reference designusing only the input for the proposed design.The calculationprocedure shall not allow the user to directly modify the building component characteristics of the standardreference design.

2. Calculation of whole-building (as a single zone) sizing for the heating and cooling equipment in the standardreference design residence in accordance with Section R403.6 R402.4.6.

3. Calculations that account for the effects of indoor and outdoor temperatures and part-load ratios on the performanceof heating, ventilating and air-conditioning equipment based on climate and equipment sizing.

4. Printed code officialinspection checklist listing each of the proposed designcomponent characteristics from TableR405.5.2(1 R404.5.2(1) determined by the analysis to provide compliance, along with their respective performanceratings (R-value, U-factor, SHGC, HSPF, AFUE, SEER, EF are some examples).

R405.6.2 R404.6.2 Specific approval. Performance analysis tools meeting the applicable provisions of Section R405 R404shall be permitted to be approved.Tools are permitted to be approvedbased on meeting a specified threshold for a jurisdiction.The code officialshall be permitted to approve tools for a specified application or limited scope.

R405.6.3 R404.6.3 Input values. When calculations require input values not specified by Sections R402, R403, R404 andR405 R404, those input values shall be taken from an approvedsource.

R406 R405 R406 R405 ENERGY RATING INDEX COMPLIANCE ALTERNATIVE

R406.1 R405.1 Scope. No change to text.

R406.2 R405.2 Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R40.5.3 R402 be met. The building thermal envelope shall be greaterthan or equal to levels of efficiency and Solar Heat Gain Coefficient in Table 402.1.1 or 402.1.3 of the 2009 International EnergyConservation Code.


R406.3 R405.3 Energy Rating Index. No change to text.

R406.3.1 R405.3.1 ERI reference design. The ERI reference design shall be configured such that it meets the minimumrequirements of the 2006 International Energy Conservation Code prescriptive requirements.

The proposed residential building shall be shown to have an annual total normalized modified load less than or equal to theannual total loads of the ERI reference design.

R406.4 R405.4 ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown tohave an ERI less than or equal to the appropriate value listed in Table R406.4 R405.4 when compared to the ERIreferencedesign.

TABLE R406.4 R405.4MAXIMUM ENERGY RATING INDEX

CLIMATE ZONE ENERGY RATING INDEX

1 52

2 52


3 51

4 54

5 55

6 54

7 53

8 53

R406.5 R405.5 Verification by approved agency. Verification of compliance with Section R406 R405 shall be completed byan approved third party.

R406.6 R405.6 Documentation. Documentation of the software used to determine the ERI and the parameters for theresidential building shall be in accordance with Sections R406.6.1 R405.6.1 through R406.6.3 R405.6.3.

R406.6.1 R405.6.1 Compliance software tools. No change to text.

R406.6.2 R405.6.2 Compliance report. Compliance software tools shall generate a report that documents that the ERI of therated design complies with Sections R406.3 R405.3 and R406.4 R405.4. The compliance documentation shall include thefollowing information:

1. Address or other identification of the residential building.2. An inspection checklist documenting the building component characteristics of the rated design. The inspection

checklist shall show results for both the ERI reference design and the rated design, and shall document all inputsentered by the user necessary to reproduce the results.

3. Name of individual completing the compliance report.4. Name and version of the compliance software tool.

Exception: Multiple orientations. Where an otherwise identical building model is offered in multiple orientations,compliance for any orientation shall be permitted by documenting that the building meets the performance requirementsin each of the four (north, east, south and west) cardinal orientations.

R406.6.3 R405.6.3 Additional documentation. The code official shall be permitted to require the following documents:

1. Documentation of the building component characteristics of the ERI reference design.2. A certification signed by the builder providing the building component characteristics of the rated design.3. Documentation of the actual values used in the software calculations for the rated design.

R406.7 R405.7 Calculation software tools. Calculation software, where used, shall be in accordance with Sections R406.7.1 R405.7.1 through R406.7.3 R405.7.3.

R406.7.1 R405.7.1 Minimum capabilities. Calculation procedures used to comply with this section shall be software toolscapable of calculating the ERI as described in Section R406.3 R405.3, and shall include the following capabilities:

1. Computer generation of the ERI reference design using only the input for the rated design.The calculationprocedure shall not allow the user to directly modify the building component characteristics of the ERI referencedesign.

2. Calculation of whole building, as a single zone, sizing for the heating and cooling equipment in the ERI referencedesign residence in accordance with Section R403.7 R402.4.6.


4. Printed code official inspection checklist listing each of the rated design component characteristics determined bythe analysis to provide compliance, along with their respective performance ratings.

R406.7.2 R405.7.2 Specific approval. Performance analysis tools meeting the applicable sections of Section R406 R405shall be approved. Tools are permitted to be approved based on meeting a specified threshold for a jurisdiction. The codeofficial shall approve tools for a specified application or limited scope.

R406.7.3 R405.7.3 Input values. No change to text.

CHAPTER 4 [RE] RESIDENTIAL ENERGY EFFICIENCY

The changes proposed to the IECC-Residential Provisions are intended for the corresponding sections of IRC Chapter 11.Reason: This proposal does not add any new requirements. This proposal simply re-formats Chapter 4[RE] to provide a clear understanding of thecompliance paths. All Mandatory requirements have been included in a separate section. The chapter is now formatted as follow s:

Section 401: GeneralSection 402: Mandatory RequirementsSection 403: Prescriptive RequirementsSection 404: Simulated Performance AlternativesSection 405: Energy Rating Index Compliance Alternative


RE16-16 : R401.2-MERES12614

The purpose of this proposal is to alleviate confusion caused w ith "Mandatory" requirements being interw oven throughout a "Prescriptive" compliancepath.

Cost Impact: Will not increase the cost of constructionThis proposal does not add any new requirements to the IECC. It simply re-formats Chapter 4[RE] to make it easier to understand and therefore does notincrease the cost of construction.


RE17-16R402.1 (IRC N1102.1)Proponent : Robert Pickett, RobPickett &Associates, LLC representing the Log & Timber Homes Council, representing Log & TimberHomes Council ([email protected]); Craig Drumheller, National Association of Home Builders, representing NationalAssociation of Home Builders ([email protected])

2015 International Energy Conservation CodeR402.1 (N1102.1) General (Prescriptive). The building thermal envelope shall meet the requirements of Sections R402.1.1through R402.1.5.

Exceptions:Exception:1. The following low-energy buildings, or portions thereof, separated from the remainder of the building bybuilding thermal envelope assemblies complying with this section shall be exempt from the building thermal envelopeprovisions of Section R402.


2. Those that do not contain conditioned space.2. Log homes designed in accordance with ICC-400.

Reason: This amendment refers design of log homes to ICC400 Standard on the Design and Construction of Log Structures (ICC400) as it is the onlyconsensus standard for log building. This amendment w ould benefit future state and local adoption as it is consistent w ith existing Stateamendments or legislation. At least four states have passed legislation referring to ICC400, w hile several other states have amended their energyconservation code to add log home specif ic paths. In 2015, the City and County of Denver adopted language similar to the proposed, and Vermontamended the 2015 IECC to add Table 402.1.5, Log Home Insulation, Fenestration and Heating Requirements by Component. Idaho added Table R402.aLog Home Prescriptive Thermal Envelope Requirements by Component to their 2014 code. Minnesota added Footnote H to Table 1102.1(1) to their2012 IECC.The design, construction and performance of log w alls are quite dif ferent than the convention construction methods detailed in the IRC (and residentialrequirements of the IECC). ICC400 responds to the thermal envelope requirements of the IRC Chapter 11 and IECC Chapter 4. The standard offersprescriptive, calculated/engineered and performance/testing paths for substantiating the performance of log w alls, and trade-off packages for eachClimate Zone. Therefore, the thermal envelope of log homes w ould be evaluated as follow s:

THERMAL: ICC400-2012 Section 305 Thermal Envelope presents requirements for w eather protection and determination of thermalproperties, offering prescriptive, calculation, and performance options. TABLE 305.3.1.2 Insulation and Fenestration Requirements byComponent provides one such prescriptive option.AIR INFILTRATION: Guidance is provided in ICC400 in Section 306 Infiltration. Section 306, along w ith 305.1 Weather protection and 304Provisions for Settling in Log Structures all w ork in unison to address the issue. The same blow er door requirement of the 2015 code shallapply to log w alls as for any other method of construction.VAPOR RETARDERS: As noted in Exception 3 of IRC Section R702.7 Vapor retarders, "Construction w here moisture or its freezing w ill notdamage the materials." There is no cavity to protect in a log w all, and all joinery is covered by ICC400-2012.EXTERIOR COVERING: The Exception in IRC Section R703.1 General refers to "Log w alls designed and constructed in accordance w ith theprovisions of ICC400." The standard covers all discussion of w eather resistance, drainage planes, etc.

The members of the Log & Timber Homes Council have encouraged certifying log homes through Energy Star® for many years. With the attention todesign and construction details in accordance w ith ICC400, log homes w ith a nominal 6" w ide log profile have been certif ied as 5-Star Plus w ith ratingsin the 50's and low er. Blow er door testing has demonstrated that log homes meet the 3ACH50 requirements of Climate Zones 4-8. These tests havedemonstrated that perhaps it is the tightness as w ell as mass of a log home that provide the satisfaction and comfort of the occupants.

It is important to note that ICC400 pertains to building solid w ood w alls and structural framing w ith logs. It defaults to the I-Codes for design conditions,foundations, roofing, mechanical, electrical, plumbing, etc. In Section 305 Thermal Envelope, ICC400 calls for compliance w ith the requirements of theIECC w ith an exception for log w alls. The thermal properties of log w alls can be taken from prescriptive tables, tested or calculated per the stipulatedequations. Application of thermal mass is described to establish conformance w ith the IECC.

Bibliography: ICC Standard on the Design and Construction of Log Structures (ICC 400)Please note: ICC copyrighted documents can only be distributed through their publications department. Electronic and print copies can be obtained fromthe ICC store at http://shop.iccsafe.org/catalogsearch/result/?order=relevance&dir=desc&q=ICC+400.

Energy Performance of Log Homes, Log & Timber Homes Council, NAHB, 2015, 42 pgs. http://loghomes.org/w p-content/uploads/2013/06/EnergyPerformanceWP_2010.pdf

Preservation & Maintenance of Log Structures, Log & Timber Homes Council, NAHB, 2003, 16 pgs. http://loghomes.org/w p-content/uploads/2013/06/Preservation-Maintenance-of-Log-Structures-10-15-03.pdf

Cost Impact: Will not increase the cost of constructionLog w all construction is an alternate method of construction from the w ood frame, steel frame, and concrete masonry options addressed in the energyconservation codes. The intent is to evaluate solid w ood w alls rather than apply prescriptive requirements that may impact the esthetic and/or durabilityof the w all system.Without this change, readers may believe that they have only three options: 1.) Build w ith very large logs, 2.) Add insulation to the outside, or 3.) Addinsulation to the inside.

Option 1: Prescriptive mass w all R-values set minimum log w idths that are not commonly available, require greater cost to build, and cannot bemilled by equipment used today. These factors w ill constrict the industry to the high-end custom home market. It w ill cause the existing log homeinventory signif icant undue stress as ow ners of otherw ise energy eff icient log homes w ill be pressed to insulate their nominal 6" log w alls(average w idth of 5"-5.5"). A survey of the industry indicates that a 10" round/8x nominal or smaller covers 80% of the log home products builtand in production in climate zones 5-8, w hich is over 55% of the log home market. The 10" round/8x nominal log size equates to an average logw idth of about 7"-7.5".

Option 2: This w ould be consistent w ith the details for cross-laminated timber (CLT).

Option 3: It should be noted that adding insulation to the inside of a log w all is not recommended as it restricts the benefits of mass w all effects


http://shop.iccsafe.org/catalogsearch/result/?order=relevance&dir=desc&q=ICC+400

RE17-16 : R402.1-PICKETT12100

w hile eliminating the opportunity for inspection that may otherw ise identify a need for maintenance.

All three options are extremely costly as opposed to trade-offs in the building thermal envelope, w hich is w hy most log home companies use REScheckfor compliance. This can help keep the log w idth to a size that is economical for production, builder and home ow ner. Therefore the cost ofconstruction can actually be reduced by evaluating log w alls by measures other than prescriptive w all R-value (R/inch of w ood).

Effect of the proposed amendment on the cost of design: __ Increase __ Reduce XXX No Effect

Effect of the proposed amendment on the cost of construction: __ Increase XXX Reduce __ No Effect

Is the amendment proposal more or less restrictive than the I-Codes? __ More __ Less XXX Same


RE18-16Table R402.1.2 (IRC Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


TABLE R402.1.2 (N1102.1.2)INSULATION AND FENESTRATION REQUIREMENTS BY COMPONENTa

CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/619

130 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5 h 8/1330

1910 /13 10, 2 ft 10/13


6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19











TABLE R402.1.4 (N1102.1.4)EQUIVALENT U-FACTORSa

CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.1650.047

0.0640.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.0980.033

0.0470.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055


RE18-16 : R402.1.2-FAY12778

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055




Reason: The purpose of this code change is to modify the requirements related to the minimum R-value and maximum U-factor for f loors to improvebuilding eff iciency in climate zones 2 and 4. This revision moves the prescriptive insulation value for f loors in Climate Zone 2 and 4 to the next nominallevel -- from R-13 to R-19 and R-19 to R-30, respectively. These proposed changes w ill yield savings in range of 1% in CZ 2 and 1.8% in CZ 4 forhomes w ith f loors over unconditioned space.

Cost Impact: Will increase the cost of constructionFor a standard-sized tw o-story single family home, the construction cost w ill increase by approximately $132 in climate zone 2 and $288 in climate zone4, per the NREL Residential Energy Eff iciency Measure Database (http://w w w .nrel.gov/ap/retrof its/group_listing.cfm). Although construction costs areincreased in this proposal, improvements to the f loor insulation requirements yield a positive life-cycle cost w hen analyzed over a 30 year period. Theanalysis used to assess this eff iciency improvement is generally based on the U.S. DOE's residential code change methodology.


http://www.nrel.gov/ap/retrofits/group_listing.cfm

RE19-16Table R402.1.2 (IRC Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, f

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE j

FLOOR

R-VALUE

BASEMENT d

WALL

R-VALUE

SLAB e

R-VALU

E & DEPTH

CRAWL

SPACEd

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.350.32 0.55 0.25 38 20 or 13+5 i 8/13 19 5/13 g 0 5/13

4 except Marine 0.350.32 0.55 0.40 49 20 or 13+5 i 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.320.30c 0.55 NR 49 20 or 13+5 i 13/17 30 h 15/19 10, 2 ft 15/19

6 0.320.30c 0.55 NR 49 20+5 or 13+10 i 15/20 30 h 15/19 10, 4 ft 15/19

7 and 8 0.320.30c 0.55 NR 49 20+5 or 13+10 i 19/21 38 h 15/19 10, 4 ft 15/19


a. R-v alues are minimums. U-f actors and SHGC are maximums. When insulation is installed in a cav ity which is less than the label or design thickness of the insulation,the installed R-v alue of the insulation shall not be less than the R-v alue specif ied in the table.

b. The f enestration U-f actor column excludes sky lights. The SHGC column applies to all glazed f enestration. Exception: Sky lights may be excluded f rom glazedf enestration SHGC requirements in climate zones 1 through 3 where the SHGC f or such sky lights does not exceed 0.30.

c. Exception: A maximum U-f actor of 0.32 shall apply in climate zone Marine 4 and climate zones 5 – 8 to v ertical f enestration products installed in buildings located: (i)abov e 4000 f eet in elev ation abov e sea lev el or (ii) in windborne debris regions where protection of openings is required under IRC section R301.2.1.2.

d. "15/19" means R-15 continuous insulation on the interior or exterior of the home or R-19 cav ity insulation at the interior of the basement wall. "15/19" shall be permittedto be met with R-13 cav ity insulation on the interior of the basement wall plus R-5 continuous insulation on the interior or exterior of the home. "10/13" means R-10continuous insulation on the interior or exterior of the home or R-13 cav ity insulation at the interior of the basement wall.

e. R-5 shall be added to the required slab edge R-v alues f or heated slabs. Insulation depth shall be the depth of the f ooting or 2 f eet, whichev er is less in Climate Zones 1through 3 f or heated slabs.

f . There are no SHGC requirements in the Marine Zone.

g. Basement wall insulation is not required in warm-humid locations as def ined by Figure R301.1 and Table R301.1.

h. Or insulation suf f icient to f ill the f raming cav ity , R-19 minimum.

i. The f irst v alue is cav ity insulation, the second v alue is continuous insulation, so "13+5" means R-13 cav ity insulation plus R-5 continuous insulation.

j. The second R-v alue applies when more than half the insulation is on the interior of the mass wall.


CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.350.32 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.350.32 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.320.30b 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.320.30b 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.320.30b 0.55 0.026 0.045 0.057 0.028 0.050 0.055

a. Nonf enestration U-f actors shall be obtained f rom measurement, calculation or an approv ed source.


RE19-16 : R402.1.2-FAY12802

b. Exception: A maximum U-f actor of 0.32 shall apply in climate zone Marine 4 and climate zones 5 – 8 to v ertical f enestration products installed in buildings located: (i)abov e 4000 f eet in elev ation abov e sea lev el or (ii) in windborne debris regions where protection of openings is required under IRC section R301.2.1.2. c. When more than half the insulation is on the interior, the mass wall U-f actors shall be a maximum of 0.17 in Climate Zone 1, 0.14 in Climate Zone 2, 0.12 in ClimateZone 3, 0.087 in Climate Zone 4 except Marine, 0.065 in Climate Zone 5 and Marine 4, and 0.057 in Climate Zones 6 through 8.

d. Basement wall U-f actor of 0.360 in warm-humid locations as def ined by Figure R301.1 and Table R301.1.

Reason: This proposal improves the U-factors for fenestration in residential buildings in climate zones 3 – 8. A market survey by ACEEE has show nthat share of w indow products meeting these requirements exceeded 80% in 2011. Seehttp://aceee.org/files/pdf/fact-sheet/Energy%20Star%20Windows%20Survey%20Results.pdfThis proposal is consistent w ith a draft proposal published by U.S. DOE earlier this year. U.S. DOE concluded that these requirements w ould be cost-effective.

This proposal also establishes an exception for fenestration installed at high altitudes (above 4000 feet in elevation) and in w indborne debris areasbecause these products suffer from eff iciency disadvantages due to product design as compared to products w ith the same frames and same low -ecoatings in the rest of the country. High altitudes typically require a breather tube in the insulating glass unit, w hich eliminates the use of argon andincreases the U-factor, w hile glazing in w indborne debris regions generally uses laminated glass, w hich can reduce the gap w idth in the insulatingglass unit, resulting in a higher U-factor. In these limited cases, this proposal leaves the U-factor requirement in climate zones Marine 4 and 5-8 at thecurrent 0.32 level.

Cost Impact: Will increase the cost of constructionGiven the level of market penetration, in many cases builders are likely already meeting the improved requirements and w ill not require an upgrade to thew indow or additional cost. How ever, in some limited cases, builders may incur increased costs. Any upgrade necessary w ould generally only requirethe relatively minimal cost of an improved low -e coating.


http://aceee.org/files/pdf/fact-sheet/Energy Star Windows Survey Results.pdf

RE20-16Table R402.1.2 (IRC Table N1101.1.2), Table R402.1.4 (IRC Table N1101.1.4)Proponent : Craig Conner, representing self ([email protected])



CLIMATE ZONE

FENESTRATION U-FACTOR b

SKYLIGHT bU-FACTOR

GLAZED FENESTRATION

SHGC b, eCEILING R-VALUE

WOOD FRAME WALL

R-VALUE

MASS WALL

R-VALUE iFLOOR R-VALUE

BASEMENT cWALL

R-VALUE

SLAB dR-VALU

E & DEPTH

CRAWL SPACE cWALL

R-VALUE1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 3830 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 exceptMarine 0.35 0.55 0.40 4938 20 or 13+5 h 8/13 19 10 /13 10, 2 f t 10/13

5 and Marine 4 0.32 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10, 2 f t 15/19

6 0.32 0.55 NR 4920+5 or 13+10

h 15/20 30 g 15/19 10, 4 f t 15/19

7 and 8 0.32 0.55 NR 4920+5 or 13+10

h 19/21 38 g 15/19 10, 4 f t 15/19












TABLE R402.1.4 EQUIVALENT U-FACTORSa

Climate Zone Fenestration

U-Factor

Skylight

U-Factor

Ceiling

U-Factor

Frame Wall

U-Factor

Mass Wall

U-Factorb

Floor

U-Factor

Basement Wall

U-Factor

Crawl Space

Wall U-Factor

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.0300.035 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except

Marine

0.35 0.55 0.0260.030 0.060 0.098 0.047 0.059 0.065

5 and

Marine 4

0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055


RE20-16 : TABLE R402.1.2-CONNER12943

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055




Reason: These insulation requirements have been show n to not be cost-effective and are being restored to (lesser) insulation levels as indicated inprevious editions of the code.

Cost Impact: Will not increase the cost of constructionNot as much insulation in these locations w ill low er building material costs and thus, low er the cost of construction.


RE21-16Table R402.1.2, (IRC Table N1102.1.2)Proponent : Jay Crandell, P.E., ARES Consulting, representing Foam Sheathing Committee of the American Chemistry Council



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E &

DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 or 0+8.5h 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 or 0+8.5h 4/6 13 0 0 0

3 0.35 0.55 0.25 38

20 or 13+ 5 4.3hor

0+13.2h8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49

20 or 13+ 5 4.3hor

0+13.2h8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.55 NR 49

20 or 13+5 4.3hor

0+13.2h13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.55 NR 49

30 or 38 or

20+5 4.8 or

13+ 10 9.6hor

0+18.7h

15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49

30 j or 38 j or

20+5 4.8 or

3+ 10 9.6hor

0+18.7h

19/21 38 g 15/19 10, 4 ft 15/19











j. R-38 applies to 2x6 f raming and R-30 applies to 2x8 f raming or double-wall wood f raming or an approv ed design.

Reason: The intent of these changes is to present cavity and continuous insulation options (including combinations of both) in all climate zones. Thisw ill help address the concerns that the energy code forces the use of certain insulation types in a given climate zone. It w ill also provide useful optionsfor each climate zone.Continuous insulation R-values are presented in a format w ith a tenth decimal place, similar to the steel-frame Table R402.2.6, and w ill help promotemore eff icient options for continuous insulation w ithout material preference.

For Climate Zones 6, 7, and 8, the cavity-only options are R-38 for 2x6 framing (using R-6.9/inch or greater cavity insulation) and R-30 for 2x8 framing(using R-4.1/inch or greater cavity insulation). While this may appear counter-intuitive, it is correct because 2x8 framing has less heat loss throughstuds (less impact of framing factor) and, thus, less cavity insulation R-value is needed in a 2x8 w all than a 2x6 w all to achieve an equivalent U-factor,all other factors equal.

Below are a series of calculations w hich justify the proposed changes to the table, demonstrating equivalency w ith the required U-factor in every case:


RE21-16 : TABLE R402.1.2-CRANDELL12864

Cost Impact: Will not increase the cost of constructionThe proposal merely provides additional options for compliance and thus, does not cause an increase in the cost of construction.



RE22-16Table R402.1.2 (IRC Table N1102.1.2)Proponent : Jay Crandell, P.E., ARES Consulting, representing Foam Sheathing Committee of the American Chemistry Council



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19





d. R-5 shall be added prov ided under the f ull slab area of a heated slab in addition to the required slab edge R -v alues f or heated unheated slabs. Insulation depth shall be as indicated in the depth of the f ooting or 2 f eet, whichev er is less in Climate Zones 1 through 3 f or heated slabs table.






Reason: This proposal improves the effectiveness of heated (radiant) slab insulation. The current practice of simply adding an additional R-5 insulationto the perimeter of a heated slab results in substantially greater heat loss from a heated slab than unheated slab w hich creates an avoidable andinappropriate energy cost penalty to consumers that use heated (radiant) slabs instead of unheated slabs. For example, ASHRAE 90.1 Appendix A(Table A6.3.1) show s that R-15 slab edge insulation only on a heated slab results in an F-factor of 1.25 w hereas R-10 slab edge insulation only on anunheated slab results in an F-factor of 0.54. Thus, there is a more than tw o-fold increase in heat loss from the heated slab than there is from theunheated slab, even though the heated slab has an additional R-5 perimeter insulation as currently required by code. This is a very ineff icient and non-equivalent w ay to insulate a heated slab. Instead, placing the additional R-5 insulation underneath a heated slab brings the performance of a heated slabmore closely in line w ith the performance of an unheated slab such that consumers do not pay for a heated slab and then also doubly pay for higherenergy costs over the life of the building. This practice w ill also provide the benefit of improved temperature control and comfort and is considered acommon and good practice for heated (radiant) slabs.

Cost Impact: Will increase the cost of constructionThat this proposal may increase cost is debatable. In many cases, radiant slabs are insulated w ith sub-slab insulation as a matter of good practice andthis is obvious to many w ho use them. In fact, at least some states already require the use of sub-slab insulation w ith heated radiant slabs. Thisproposal w ill also decrease long-term costs of operating a heated slab in comparison to use of an unheated slab w ith perimeter insulation only. Thereare also practical and cost-saving advantages of not increasing perimeter insulation thickness, particularly w hen placed in its most effective location onthe exterior side of the slab edge.



RE23-16R402.1.2 (IRC N1102.1.2)Proponent : Jay Crandell, P.E., ARES Consulting, representing Foam Sheathing Committee of the American Chemistry Council



CLIMATE ZONE

FENESTRATION U-FACTOR b

SKYLIGHTb

U-FACTOR

GLAZED FENESTRATION

SHGC b, e

CEILING R-VALUE

WOOD FRAMEWALL

R-VALUE

MASS WALL

R-VALUE i c FLOOR R-

VALUE

BASEMENT cWALL

R-VALUE

SLAB dR-VALUE & DEPTH

CRAWL SPACE cWALL

R-VALUE

InteriorInsulation

Method

ExteriorInsulation

Method Unheated

SlabHeatedd

Slab

1 NR 0.75 0.25 30 133/ 4 or

0+3cih2.4ci 13 0 0 5ci, 2 f t 0

2 0.40 0.65 0.25 38 134/ 6 or

0+4.6cih3.4ci 13 0 0 5ci, 2f t 0

3 0.35 0.55 0.25 38 20 or 13+5cih8/ 13 or

0+9cih7.5ci 19 5ci or 135/13 f 0 5ci, 2 f t

5ci or 13f 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5cih8/ 13 or

0+9cih7.5ci 19 10ci or 1310

/13 10ci, 2 ft 15ci, 2 f t 10ci or1310/13

5 and Marine 4 0.32 0.55 NR 49 20 or 13+5cih

13/ 17 or

11+4.8ci or13+3.8ci orR15+2.9ci

or

0+12.8cih

9.4ci 30 g15ci or

13+5cihor15/ 1910ci, 2 ft 15ci, 2 f t

15ci or

13+5cih

or15/ 19

6 0.32 0.55 NR 4920+5ci or

13+10cih

15/ 20 or11+6.3ci or13+5.2ci or15+4.2ci or

0+14.3cih

14ci 30 g 15ci or

13+5cihor15/ 1910ci, 4 ft 15ci, 4 f t

15ci or

13+5cih

or15/ 19

7 and 8 0.32 0.55 NR 4920+5ci or

13+10cih

19/ 21 or11+6.8ci or13+5.7ci or15+4.7ci or

0+14.9cih

14.8ci 38 g 15ci or 13+5cih

or15/ 1910ci, 4 ft 15ci, 4 f t

15ci or

13+5cih

or15/ 19





c. Mass walls shall be insulated using an interior insulation method or an exterior insulation method. Where cav ity insulation is installed, such insulation shall be installed onthe interior side of the wall and between wood f raming members. Where only continuous insulation (ci) is installed on the wall or is installed in combination with cav ityinsulation, the continuous insulation shall be installed on the interior or exterior surf ace of the wall in accordance with the selected insulation method. The installation of anymetal or wood f raming materials shall be ov er the continuous insulation.

d. For R-5 shall be added to Climate Zones 1 through 3, the required slab edge R -v alues f or heated slabs. Insulation insulation depth shall not be required to be greaterthan the depth of the f ooting or 2 f eet, whichev er is less in Climate Zones 1 through 3 f or heated slabs.




h. The f irst v alue is cav ity insulation, the second v alue is continuous insulation (ci), so "13+5 5ci" means R-13 cav ity insulation plus R-5 continuous insulation.


Reason: This proposal provides clarity in regard to insulation locations or placement (e.g., cavity insulation, continuous insulation, and combinations ofsuch). This also enables the inclusion of additional options for mass w alls for exterior and interior insulation strategies. For the interior insulationstrategy on mass w alls, options include cavity insulation only, cavity plus continuous insulation, and continuous insulation. Thus, providing a full suite ofinsulation placement options enabling also a full suite of insulation materials and methods. With these clarif ications and options, enforcement should beimproved w hile also providing options that best f it a given project. The actual R-value for mass w alls are "f ine tuned" (in many cases slightly reduced) tobetter agree w ith U-factors for mass w alls and more eff icient designs. Similar clarif ications are made to basement w all and craw lspace w all insulationrequirements w hich include options from footnotes directly in the table for improved useability. No technical changes are made in those cases. Inaddition, heated slabs and unheated slabs are treated separately in the table to avoid using a footnote requiring insulation to be added to valuesreported in the table (thus the footnote is deleted). All of these changes w ill add options and improve clarity of the table and are consistent w ith U-factor requirements in the code such that there are effectively no technical changes (increases or decreases) in the intended energy eff iciency.

Cost Impact: Will not increase the cost of constructionThis proposal is a clarif ication and provides additional options w hich may actually decrease costs in some cases.


RE24-16Table R402.1.2 (IRC Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4)Proponent : Thomas Culp, Birch Point Consulting LLC, representing the Glazing Industry Code Committee([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.750.70 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 except Marine 0.350.32 0.55 0.40 49 20 or 13+5 h 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.320.30j 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10, 2 ft 15/19

6 0.320.30j 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.320.30j 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19











j. Windows with a U-factor = 0.31 having a SHGC ≥ 0.35, and windows with a U-factor = 0.32 having a SHGC ≥ 0.40 shall beconsidered in compliance with the requirement for a U-factor not greater than 0.30.


CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.70 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.350.32 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.30 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.30 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.30 0.55 0.026 0.045 0.057 0.028 0.050 0.055



RE24-16 : TABLE R402.1.2-CULP12535



Reason: This proposal updates the prescriptive fenestration requirements based upon the previous version of the Energy Star program for Window s,Doors, and Skylights (version 5, 2010). EPA recently updated the criteria for Energy Star (version 6, 2015) in part because Energy Star products hadbecome ubiquitous, penetrating over 80% of the market for w indow s, and over 70% of the market for doors and skylights back in 2010, and presumablyeven higher now . [Reference 1, page 8.] Therefore, as the products are already being w idely used, it is cost effective and makes sense to update theIECC criteria to be consistent w ith the older Energy Star criteria.

The proposed changes are consistent w ith version 5 of Energy Star [reference 2], except w here the IECC is already the same or more stringent: zones1-3 U-factor and zones 1-3 SHGC for vertical fenestration, zones 2-8 U-factor for skylights. The Energy Star program also includes limited equivalentenergy performance U / SHGC combinations for the northern zones; these are included as a footnote in Table R402.1.2. (It is not necessary to includethis footnote in Table R402.1.4, w hich is only used as basis for UA and performance path trade-offs.)

It should be noted that another proposal being submitted by the Department of Energy to update the prescriptive fenestration criteria is not completelyconsistent w ith version 5 of the Energy Star program. The DOE proposal has a low er vertical fenestration U-factor in zone 3 not included in Energy Starversion 5, fails to low er the skylight U-factor in zone 1 to match Energy Star version 5, and completely omits the equivalent energy performance U /SHGC combinations from Energy Star version 5 in the northern zones. (EPA also included equivalent energy performance combinations for the northernzones in the new Energy Star version 6, after reconfirming their value and validity.) Therefore, this proposal is more complete w hile still satisfying thesame intent of updating the fenestration criteria.

Bibliography:

1. ENERGY STAR® for Window s, Doors, and Skylights Version 6.0 Draft 1 Criteria and Analysis Report, U.S. EPA, July 2012.http://w w w .energystar.gov/sites/default/f iles/specs//Draft6_V1_Criteria_Analysis_Report.pdf, page 8.

2. ENERGY STAR®� Program Requirements for Residential Window s, Doors, and Skylights – Version 5.0, U.S. DOE and EPA, April 2009.http://w w w .energystar.gov/sites/default/f iles/specs//Window sDoorsSkylightsProgRequirements7Apr09.pdf

Cost Impact: Will not increase the cost of constructionThe EPA has cited that Energy Star products under the previous Energy Star requirements (upon w hich this proposal is based) had penetrated over80% of the market in 2010 for w indow s, and over 70% of the market for doors and skylights. [Reference 1, page 8] The percentage is likely even highernow that companies are adjusting to the new Energy Star criteria. As such, the products to meet the criteria in this proposal are ubiquitous, and anycost impact is minimal.


http://www.energystar.gov/sites/default/files/specs//Draft6_V1_Criteria_Analysis_Report.pdf

http://www.energystar.gov/sites/default/files/specs//WindowsDoorsSkylightsProgRequirements7Apr09.pdf

RE25-16Table R402.1.2 (IRC Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4), R402.2.13 (IRCN1102.2.13), R402.4.1.2 (IRC N1102.4.1.2), R402.5 (IRC N1102.5), Table R405.5.2(1) [IRC TableN1102.5.5.2(1)], Table R406.4 (IRC Table N1102.1.2)Proponent : Steven Ferguson, representing American Society of Heating, Refrigerating and Air-Conditioning Engineers([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

0 and 1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19



b. The f enestration U -f actor column excludes sky lights. The SHGC column applies to all glazed f enestration. Exception: Sky lights may be excluded f rom glazedf enestration SHGC requirements in climate zones 1 0 through 3 where the SHGC f or such sky lights does not exceed 0.30.


d. R-5 shall be added to the required slab edge R -v alues f or heated slabs. Insulation depth shall be the depth of the f ooting or 2 f eet, whichev er is less in Climate Zones 1 0 through 3 f or heated slabs.







CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

0 and 1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055


b. When more than half the insulation is on the interior, the mass wall U-f actors shall be a maximum of 0.17 in Climate Zone Zones 0 and 1, 0.14 in Climate Zone 2, 0.12


in Climate Zone 3, 0.087 in Climate Zone 4 except Marine, 0.065 in Climate Zone 5 and Marine 4, and 0.057 in Climate Zones 6 through 8.


R402.2.13 (N1102.2.13) Sunroom insulation. Sunrooms enclosing conditioned space shall meet the insulation requirementsof this code.

Exception: For sunrooms with thermal isolation, and enclosing conditioned space, the following exceptions to theinsulation requirements of this code shall apply:

1. The minimum ceiling insulation R-values shall be R-19 in Climate Zones1 0 through 4 and R-24 in ClimateZones 5 through 8.

2. The minimum wall R-value shall be R-13 in all climate zones. Walls separating a sunroom with a thermalisolation from conditioned space shall meet the building thermal envelope requirements of this code.

R402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 0 through 2, and three air changes per hour in Climate Zones 3through 8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inchw.g. (50 Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written reportof the results of the test shall be signed by the party conducting the test and provided to the code official. Testing shall beperformed at any time after creation of all penetrations of the building thermal envelope.

During testing:




R402.5 (N1102.5) Maximum fenestration U-factor and SHGC (Mandatory). The area-weighted average maximumfenestration U-factor permitted using tradeoffs from Section R402.1.5 or R405 shall be 0.48 in Climate Zones 4 and 5 and 0.40in Climate Zones 6 through 8 for vertical fenestration, and 0.75 in Climate Zones 4 through 8 for skylights. The area-weightedaverage maximum fenestration SHGC permitted using tradeoffs from Section R405 in Climate Zones 1 0 through 3 shall be0.50.

TABLE R405.5.2(1) [N1105.5.2(1)]SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS

Portions of Tab le not shown remain unchanged.BUILDING COMPONENT STANDARD REFERENCE DESIGN PROPOSED DESIGN

Abov e-grade walls

Ty pe: mass wall if proposed wall is mass; otherwise wood f rame. As proposed

Gross area: same as proposed As proposed

U-f actor: as specif ied in Table N1102.1.4 As proposed

Solar absorptance = 0.75 As proposed

Emittance = 0.90 As proposed

Basement and crawl spacewalls

Ty pe: same as proposed As proposed


U-f actor: f rom Table N1102.1.4, with insulation lay er on interior side ofwalls As proposed

Abov e-grade f loors

Ty pe: wood f rame As proposed



Ceilings




Roof s

Ty pe: composition shingle on wood sheathing As proposed




Attics Ty pe: v ented with aperture = 1 f t2 per 300 f t2 ceiling area As proposed

FoundationsTy pe: same as proposed As proposed

Foundation wall area abov e and below grade and soil characteristics:same as proposed As proposed

Opaque doorsArea: 40 f t2 As proposed

Orientation: North As proposed

U-f actor: same as f enestration f rom Table N1102.1.4 As proposed

Vertical f enestration other

Total areah =

As proposed(a)The proposed glazing area, where the proposed glazing area is less

than 15 percent of the conditioned f loor area(b)15 percent of the conditioned f loor area, where the proposed glazing

area is 15 percent or more of the conditioned f loor area

Orientation: equally distributed to f our cardinal compass orientations


RE25-16 : TABLE R402.1.2-FERGUSON12883

than opaque doors (N, E, S & W). As proposed


SHGC: as specif ied in Table N1102.1.2 except that f or climates with norequirement (NR) SHGC = 0.40 shall be used. As proposed

Interior shade f raction: 0.92-(0.21 × SHGC f or the standard ref erencedesign) 0.92-(0.21 × SHGC as proposed)

External shading: none As proposed

Sky lights None As proposed

Thermally isolated sunrooms None As proposed

Air exchange rate

Air leakage rate of 5 air changes per hour in Climate Zones 0, 1 and 2,and 3 air changes per hour in Climate Zones 3 through 8 at a pressureof 0.2 inches w.g (50 Pa). The mechanical v entilation rate shall be in

addition to the air leakage rate and the same as in the proposed design,but no greater than 0.01 × CFA + 7.5 ×(Nbr + 1)

where:CFA = conditioned f loor area Nbr = number of bedrooms

Energy recov ery shall not be assumed f or mechanical v entilation.

For residences that are not tested, the same air leakage rate as thestandard ref erence design.

For tested residences, the mea-

sured air exchange ratea .

The mechanical v entilation rateb

shall be in addition to the air leakage rate and shall be as proposed.

Notes to Tab le not shown for clarity and remain unchanged.

TABLE R406.4 (N1106.4)MAXIMUM ENERGY RATING INDEX


0 and 1 52

2 52

3 51

4 54

5 55

6 54

7 53

8 53

Reason: This proposal updates the climate zones to correspond w ith the release of ASHRAE Standard 169-2013, Climatic Data for Building DesignStandards. Standard 169-2013 includes more-recent w eather data and the creation of a new Climate Zone 0. Approximately 10% of the counties in theUnited States have a change in Climate Zone designation due to this change, w ith most of these changes resulting in a change to w armer climatezones.

Generally, the new Climate Zone 0 is the hotter portion of the previous Climate Zone 1, w hich w as the w armest climate zone. Cities in Climate Zone 0include Mumbai (Bombay), Jakarta and Abu Dhabi. There are no cities in the United States in Climate Zone 0; Miami and the islands of Haw aii are inClimate Zone 1. The separation of Climate Zones 0 and 1 allow s separate criteria for IECC to be developed that are more specif ic to the hotter regions ofClimate Zone 0.

The changes for Part II repeat all of the criteria for Climate Zone 1 for Climate Zone 0. This represents no increase or decrease in stringency for ClimateZone 0 and thus, no increase in the cost of construction.

Cost Impact: Will not increase the cost of constructionThis represents no increase or decrease in stringency for Climate Zone 0 and no increase in the cost of construction.


RE26-16 : TABLE R402.1.2-FISCHER13309

RE26-16Table R402.1.2 (IRC Table N1102.1.2)Proponent : Mike Fischer, Kellen Company,representing Polyisocyanurate Insulation Manufacturers Association([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT

b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE:

CAVITY

INSULATION

ONLY

WOOD FRAME

WALL

R-VALUE:

COMBINATION

CAVITY AND

CONTINUOUS

INSULATION

(ci)

WOOD FRAME

WALL

R-VALUE:

CONTINUOUS

INSULATION

(ci) ONLY

MASS

WALL

R-

VALUE

i

FLOOR

R-

VALUE

BASEMENT

c

WALL

R-VALUE

SLAB d

R-VALU

E &

DEPTH

CRAWL

SPACE

c

WALL

R-

VALUE

1 NR 0.75 0.25 30 13 - 9ci 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 - 9ci 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 13+5 h 14ci 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5 h 13+5 h 14ci 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.55 NR 49 20 or 13+5 h 13+5 h 14ci 13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.55 NR 4930j 20+5 or

13+10 h

20+5 h or 13+10

h19ci 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 4930j 20+5 or

13+10 h

20+5 h or 13+10

h19ci 19/21 38 g 15/19 10, 4 ft 15/19











j. Requires 2 x 8 wall f raming.

Reason: The prescriptive R-Value table in the IECC contains limited options for dif ferent combinations of w all insulation materials using cavity insulationalone or in conjunction w ith continuous insulation installed on the outside of the w all framing. This proposal revises the table and provides R-Valueoptions for cavity insulation and continuous insulation in all climate zones that meet or exceed the U-Factor requirements in Table 402.1.4, w hile retainingthe current combination assemblies.

Cost Impact: Will not increase the cost of constructionThe proposal adds no mandatory requirements, but increases the f lexibility of the code by providing additional compliance options. Flexbility in the codestend to low er costs of construction.


RE27-16 : TABLE R402.1.2-FISCHER13325

RE27-16Table R402.1.2, (IRC Table N1102.1.2)Proponent : Mike Fischer, Kellen Company, representing Polyisocyanurate Insulation Manufacturers Association([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

CONTINUOUS

INSULATION (ci)

ROOF DESIGNj

WOOD

FRAME

WALL

R-VALUE

MASS

WALL

R-VALUE

i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E &

DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 28 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 34 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 34 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 38 20 or 13+5 h 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.55 NR 49 38 20 or 13+5 h 13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.55 NR 49 38 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 38 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19











j. Requires uncompressed continuous insulation extending ov er the top plate of the wall at eav es.

Reason: The prescriptive R-Value table in the IECC contains an option for traditional ceiling insulation installed betw een and around roof trussassemblies, but does not contain an R-Value option for continuous insulation. With the increase in the use of continuous insulation in roof assemblies,w hether through advanced roof framing, SIPS panels, or other systems, it is appropriate to include that option, w ith values that meet the U-Factorrequirements in Table R402.1.4, in Table 402.1.2.

Cost Impact: Will not increase the cost of constructionThe proposal provides additional f lexibility but no mandatory requirements. Thus, there is no impact to the cost of construction.


RE28-16R402.1.2 (IRC: N1102.1.2)Proponent : Tom Kositzky, representing Coalition for Fair Energy Codes; Mark Halverson, representingAPA ([email protected]); Loren Ross, representing American Wood Council ([email protected]); Greg Johnson,representing Coalition for Fair Energy Codes ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.32 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13


5 and Marine 4 0.320.30 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10, 2 ft 15/19

6

0.320.30 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

0.26 0.55 NR 49 25 15/20 30g 15/19 10 , 4f t 15/19

7 and 8

0.320.30 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19

0.26 0.55 NR 49 25 19/21 38g 15/19 10, 4 f t 15/19











Reason: This proposal adds a prescriptive cavity-only w all insulation option in Climate Zones 6-8 w here none currently exists. This new path providesequivalent energy performance by combining the proposed R25 w ood frame w all R-value w ith better performing w indow s (U=0.26), such thatequivalent energy performance is achieved. The proposed change provides f lexibility to builders w ho use the prescriptive table but prefer to not usecontinuous insulation. The proposal also changes the fenestration U-factors in Climate Zones 3-8 to match the levels proposed for the 2018 IECC by theU.S. Department of Energy. In recent years, states w ith Climate Zones 6-8 have commonly amended the w ood frame w all requirements to allow R20 cavity-only insulation, resultingin a less energy eff icient code. This has been done, in part, to maintain an alternative to the prescriptive continuous insulation mandate in the modelenergy code. This proposal provides a w all cavity insulation level that can still w ork w ith 2x6 framing, yet is signif icantly higher than R20 insulation. While the proposal is energy neutral w ith the model code, it actually has the potential to produce signif icant energy savings at reduced cost due to lesslocal resistance to model energy code adoption and few er incentives for states to amend the w ood w all insulation requirements to low er levels.

This new Climate Zone 6-8 option has been evaluated using both a total UA and energy simulation approach and w as found to have better performancethan the current R20+5 continuous insulation requirement and the current fenestration U-factor requirements in the 2015 IECC. The proposal w as alsofound to be energy neutral w hen the DOE proposed 2018 IECC fenestration U-factor levels are assumed.

A Total UA analysis w as performed comparing the proposed option w ith a variety of IECC-compliant continuous insulation options.


Total UA Analysis Background Information


RE28-16 : TABLE R402.1.2-KOSITZKY13215

Energy Simulation Comparing an Improved 2015 IECC with the Proposed Cavity Insulation PathThis simulated w hole building analysis w as modeled using the US Department of Energy's prototype single family home in the report, DOE Methodologyfor Evaluating cost Effectiveness of Residential Energy Code Changes¹. The energy simulation w as completed using RemDesign 14.6.1, one of themost w idely used accredited energy rating tools. The results demonstrate that a house in Climate Zone 6 w ith R-25 cavity insulation and 0.26 U-factorw indow s uses only 0.04 percent more energy per year than a house built according to an improved 2015 IECC baseline that includes the proposed new0.30 U-factor w indow s and R20+5 insulation (w hich also includes the added benefit of tw o continuous layers of w all sheathing). The 0.04 percentincrease in annual energy use w ould result in 0.07 MMBTU's per year, roughly equating to $6 more in annual energy cost per year. This analysis onlyevaluated differences in above grade opaque w alls and w indow s. All other building components and systems w ere identical in the analysis. ¹Home characteristics taken from the US Department of Energy's, Methodology for Evaluating cost Effectiveness of Residential Energy Code Changes,published August 2015.

Cost Impact: Will increase the cost of constructionThis proposal does result in higher construction costs but only in respect to the decreased w indow U-factors for Climate Zones 3-8. The optional w allinsulation/w indow path proposed for Climate Zones 6-8 w ill not increase the cost of construction, since the existing continuous insulation w allassemblies remain unchanged. The addition of the proposed prescriptive w all insulation path merely provides and option, w hich could result in reducedconstruction costs over the existing continuous insulation assemblies in Table R402.1.2.

According to the U.S. Department of energy's cost-effectiveness methodology, the proposed low er fenestration U-factors show a positive life-cyclecost savings in climate Zones 3 through 8.(Α)

(Α) https://w w w .energycodes.gov/development/2018IECC#residential


https%3A//www.energycodes.gov/development/2018IECC#residential

https%3A//www.energycodes.gov/development/2018IECC#residential

RE29-16 : TABLE R402.1.2-NORMAN11808

RE29-16Table R402.1.2 (IRC Table N1102.1.2)Proponent : Phillip Norman, representing self ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 g 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 g 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 g 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5 h 8/13 19 g 10 /13 10, 2 ft 10/13


6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19









g. Floor insulation shall be in f ull contact with ov erhead sheathing and shall be retained by an underside air barrier. If the air barrier is set against joist bottom f aces, bay smust be ov er-f illed, generally compressed to much less than batt f ree thickness. An excess of insulation, more than label R30, shall be required f or common 7.25" joistdepths if batts and air barrier material are not raised to make contact with the subf loor, abov e joist bottom f aces. Where a crawl space or unconditioned basement does not f ollow outdoor temperature extremes, with outdoor v ents saf ely , easily and assuredly closed during colder weather, air barrier-f aced battsshall achiev e f loor R-v alue 19 in any climate zone.

The f actors to be regulated now are only intimate f loor contact and the presence of underside air barrier. Where this calls f or large rev ision of practices, including banning ofretention with joist-f ace twining, code shall respond to the ev olv ing new practices at f uture rev ision.



Reason: Insulation that is not in full contact w ith the air barrier of the heated f loor, has little value. Further, any gaps betw een the insulation and thefloor are inviting habitat for vermin, then w ith further destruction of insulation value, ruin of insulation and fouling of the basement or craw l space.Protection against such gaps may be diff icult w here batts have uneven thickness and little resistance of compression or offer of spring-back. It w ill bebetter to give up some insulation value in compression, than to permit voids. Start then w ith batts amply thick. An underside air barrier may be solid,aiding in uniform batt retention and compression.

Cost Impact: Will increase the cost of constructionCareful, durable insulation costs more, but ineffective insulation, repaired, costs yet more.


RE30-16Table R402.1.2 (IRC Table N1102.1.2)Proponent : Donald Surrena ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h,j 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.55 0.40 49 20 or 13+5 h,j 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.55 NR 49 20 or 13+5 h,j 13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.55 NR 49 20+5 or 13+10 h,j 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h,j 19/21 38 g 15/19 10, 4 ft 15/19











j. R-18 insulation shall be permitted in place of the R-20 requirement provided that the wall framing factor is 20% or less of exteriorwalls having 24 inch o.c. nominal vertical stud spacing.

Reason: The ASHRAE Handbook of Fundamentals and ASHRAE Transaction 1995 Volume 101, Part 2 assumes that w ood framed w alls have a framingfactor of 25%. Meaning 25 percent of the w all area consists of structural framing members and the remainder of the w all is a cavity suitable forinstalling insulation. When calculating the U-factor for a w all assembly, a high framing factor increases the overall assembly U-Factor. Reducing theframing factor w ill also provide an increase in the thermal performance of the w all.

This proposal provides an option for a thermally equivalent tradeoff for 2x6 w all assemblies w hich have reduced framing factors and R-18 insulation.Below are the calculations show ing equal U-Factors for both assemblies (0.060).


RE30-16 : TABLE R402.1.2-SURRENA12441

Enermodal, 2001. Characterization of Framing Factors for Low -Rise Residential Building

Envelopes (904-RP). Final Report prepared for ASHRAE, Atlanta, GA (USA)

Cost Impact: Will not increase the cost of constructionThis proposal offers an optional w ay to compliance, by allow ing a framing and insulation alternative to w hat is currently in the code w ithout reducing theoverall eff iciency.


RE31-16Table R402.1.2 (IRC Table N1101.1.2), R402.1.4 (IRC Table N1101.1.4)Proponent : Donald Surrena ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.350.32 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.320.30 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.320.30 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.32 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.350.32 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.320.30 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.320.30 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.320.30 0.55 0.026 0.045 0.057 0.028 0.050 0.055






Reason: Window efficiency has been aggressively targeted by programs such as ENERGY STAR because, compared to opaque walls, windowsresult in a much higher heat loss. Many Building America projects after 2010 incorporate window U-factors as low as 0.27, especially in cold climates,indicating that low-U glazing is finding widespread use in the marketplace.[1] Given these developments, this code change proposal considersimproving maximum allowable fenestration U-factors to match older ENERGY STAR specifications where data indicate there is substantial marketpenetration. According to the 2013 ENERGY STAR market assessment conducted by Ducker Worldwide, the overall ENERGY STAR penetration forresidential windows in the year 2013 was estimated to be 80%.[2] For new construction alone, ENERGY STAR residential window market penetrationranges from 70% to 88% based on climatic region, except for Florida which has a lower penetration rate of 36%. This proposed change only affectsclimate zones 3 through 8, for which data indicate excellent market penetration. It can thus be concluded that the current residential building marketis sufficiently primed for lowering window U-factors in these climate zones.Energy Savings: DOE's analysis of the energy impact of this proposed change found energy savings in climate zones 3 through 8. Savings rangedfrom about 0.6% to 1.1% of IECC-regulated end uses (heating, cooling, water heating, and lighting). The U.S. Department of Energy (DOE) develops its proposals through a public process to ensure transparency, objectivity and consistency inDOE-proposed code changes. Energy savings and cost impacts are assessed based on established methods and reported for each proposal, asapplicable. More information on the process utilized to develop the DOE proposals for the 2018 IECC can be found at:https://w w w .energycodes.gov/development/2018IECC.

Cost Impact: Data collected by DOE indicates an incremental cost of $0.18/ft2 for a window with a U-factor of 0.30 compared to a window with a U-factor of 0.35.

[3] The present analysis conservatively assumes the same incremental cost of $0.18/ft2 for windows with a U-factor of 0.32 compared to

windows with a U-factor of 0.35.

[1] See Case Studies in the "cold/very cold" regions in the Building America Solution Center at https://basc.pnnl.gov/optimized-climate-solutions/coldvery-cold

[2] Available from ENERGY STAR by request

[3] Residential Energy Eff iciency Measures – Prototype Estimate and Cost Data available at http://bc3.pnnl.gov/sites/default/f iles/Residential_Report.pdf

Cost Impact: Will not increase the cost of constructionCost Impact: Data collected by DOE indicates an incremental cost of $0.18/ft2 for a window with a U-factor of 0.30 compared to a window with a U-

factor of 0.35.[3]

The present analysis conservatively assumes the same incremental cost of $0.18/ft2 for windows with a U-factor of 0.32 compared towindows with a U-factor of 0.35.Cost-effectiveness: Assuming windows have a useful life of 30 years, an evaluation of the life-cycle cost savings of these improved levels over the2015 IECC requirements using DOE's cost-effectiveness methodology shows positive life-cycle cost savings in climate zones 3 to 8. Life-cyclesavings range from about $16 in zone 3 to $388 in zone 8.


#_ftn1

#_ftn2


#_ftn3

#_ftnref1

https://basc.pnnl.gov/optimized-climate-solutions/coldvery-cold

#_ftnref2

#_ftnref3

http://bc3.pnnl.gov/sites/default/files/Residential_Report.pdf

#_ftn3

RE32-16Table R402.1.2 (IRC Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4)Proponent : Donald Surrena ([email protected])


TABLE R402.1.2 (N1102..1.2)INSULATION AND FENESTRATION REQUIREMENTS BY COMPONENTa

CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.32 0.55 NR 49

20+5 or

13+1020 or

13+5 h

15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 0.026 0.0450.057 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055






Reason: The prescriptive wall requirement increased to R-20+R5 in climate zones 6 in the 2012 IECC. The additional cost for this is estimated at$1,819 for 1,016 square feet of wall. This makes the simple payback 55 years for climate zone 6.Climate Zone Representativ e City Wall R-Value Change Energy Sav ings Incremental Cost Simple Pay back

6 Minneapolis, MN R-20->R-20+5 $33/y r $1,819 55 y ears

Not only is the simple payback extremely long, but for a consumer, there would be a negative cash flow based on the incremental cost and energysavings. The increase in the monthly mortgage would be $12.00 (@ 5%) and the average monthly energy savings would be $2.75 in Zone 6 causingthe home owner to pay more in additional monthly mortgage payments than the energy savings returns.The cost difference between R13 wall insulation to R20 or R13 + 10 insulation in climate zone 6 is roughly $1,819. The energy savings isapproximately $33 a year.1 Increasing a $250,000, 20 year mortgage by $1,819 at 5% interest is approximately $12 per month.2 That's a cost of $144per year, for $33 a year savings. This results in $111 a year negative cash flow, it will take 122 years to recuperate the initial cost and carrying costjust to break even.

As far as cash flow, until the 123rd year there is no savings. Simple Payback will take 55 years.This is not how we run our homes buying products that have negligible benefit and take over a century to recover our costs._________________

1. The energy modeling was done using the Energy Plus simulation engine and BEopt version 1.4, Cost figures came from ASHRAE RP-1481.2. http://www.amortization-calc.com/

Cost Impact: Will not increase the cost of constructionThis w ould require less materials and save the home ow ner money on their mortgage.


http://www.amortization-calc.com/




CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+513 h 8/13 19 5/13 f 0 5/13



6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.0600.084 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055






Reason: Frame wall requirements in Climate Zone 3 changed from R-13 to R-13+5 or R-20, which is not cost effective for the consumer.

Climate Zone Representativ e City Wall R-Value Change Energy Sav ings Incremental Cost Simple Pay back

3 Atlanta, GA R-13->R-20 $50/y r $1,199 24 y ears

Not only is the simple payback extremely long, but for a consumer, there would be a negative cash flow based on the incremental cost and energysavings. The increase in the monthly mortgage would be $6.43 (@ 5%) and the average monthly energy savings would be $4.17 in Zone 3 causing thehome owner to pay more in additional monthly mortgage payments than the energy savings returns.The cost difference between R13 wall insulation to R13+5 or R20 insulation in climate zone 3 is roughly $1,199. The energy savings is approximately$50 a year.1 Increasing a $250,000, 20 year mortgage by $1,199 at 5% interest is approximately $6.43 per month.2 That's a cost of $77.16 per year,for $50 a year savings. This results in $27.16 a year negative cash flow, it will take 33 years to recuperate the initial cost and carrying cost just tobreak even.Until the 34th year there is no savings.The values being modified by this proposal are the same as what DOE proposed for the 2012 code. The values currently adopted were an increasefrom proposals not submitted by DOE._______________

The energy modeling was done using the Energy Plus simulation engine and BEopt version 1.4, Cost figures came from ASHRAE RP-1481.


Cost Impact: Will not increase the cost of constructionApproving this proposal w ill reduce the amount of materials needed as w ell as low er the consumers mortgage amount and payments.






CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13


5 and Marine 4 0.32 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10/13 10, 2 ft 15/19

6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.0500.059 0.055

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055






Reason: This proposal reduces the basement w all insulation value requirements in Climate Zone 5 to the values in the 2009 IECC. The prescriptivebasement w all requirements increased from R010 to R-15 in the 2012 IRC and in the 2012 IECC provisions. Calculations used to justify the change w erebased on energy models w hich had less sophisticated algorithms than Energy Plus, now the modeling softw are used by the Department of Energy(DOE). When using Energy Plus, the savings in a typical 700 square foot basement totaled $ 7 per year in Chicago, a Climate Zone 5 city. The additionalcost for this is conservatively estimated at $ 590. This makes the simple payback in excess of eighty-four years. The values being modif ied by thisproposal are the same w as w hat w as proposed by DOE in proposal EC13 from the 2009 code cycle. Energy modeling w as performed using the EnergyPlus simulation engine and BEopt version 1.4 and the cost f igures came from ASHRAE RP-1481.For designers and builders that have chosen to insulate on the exterior side of the basement foundation w all this reduction from R-15 to R-10 w ill allowfor the installation of approximately tw o inch thick rigid foam boards or f iber insulation board products that are typically readily available at retail storesand commercial construction suppliers. The three-inch thick R-15 insulation products typically w ill also require special order f lashing w hen installed onthe exterior side of the basement foundation w all.

Cost Impact: Will not increase the cost of constructionThis modif ication to the required R-values of basement foundation w all insulation w ill decrease the cost of construction because of the reduction in theamount of insulation required to meet the minimum R-value specif ied, typically reducing the insulation thickness from approximately three inches dow n toapproximately tw o inches.


RE35-16Table R402.1.2 (Table N1102.1.2), Table R402.1.4 (IRC Table N1102.1.4), R103.2 (IRC N1101.5)Proponent : Lauren Urbanek, Natural Resources Defense Council ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR0.40 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.350.30 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.320.27 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.320.27 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.500.40 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.350.30 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.350.30 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.320.27 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.320.27 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.320.27 0.55 0.026 0.045 0.057 0.028 0.050 0.055





RE35-16 : TABLE R402.1.2-URBANEK12669

R103.2 (N1101.5) Information on construction documents. Construction documents shall be drawn to scale upon suitablematerial. Electronic media documents are permitted to be submitted where approved by the code official. Constructiondocuments shall be of sufficient clarity to indicate the location, nature and extent of the work proposed, and show in sufficientdetail pertinent data and features of the building, systems and equipment as herein governed. Details shall include, but are notlimited to, the following as applicable:

1. Insulation materials and their R-values.2. Fenestration U-factors and solar heat gain coefficients (SHGC).3. Area-weighted U-factor and solar heat gain coefficients (SHGC) calculations.4. Mechanical system design criteria.5. Mechanical and service water-heating system and equipment types, sizes and efficiencies.6. Equipment and system controls.7. Duct sealing, duct and pipe insulation and location.8. Air sealing details.

1. Cardinal directions2. Insulation materials and their R-values.3. Fenestration U-factors and solar heat gain coefficients (SHGC).4. Area-weighted U-factor and solar heat gain coefficients (SHGC) calculations.5. Mechanical system design criteria.6. Mechanical and service water-heating system and equipment types, sizes and efficiencies.7. Equipment and system controls.8. Duct sealing, duct and pipe insulation and location.9. Air sealing details.

Reason: This proposed change to the fenestration U-factor aligns the IECC w ith the ENERGY STAR Version 6.0 specif ication. The ENERGY STARstandard for w indow s in climate zones 1-4 has been in place since January 1, 2015. The ENERGY STAR standard for w indow s in climate zones 5-8has been in place since January 1, 2016. By the time the 2018 code is adopted, manufacturers w ill have time to adjust their product line to includeproducts that meet the ENERGY STAR standard, and therefore the code.

Replacing old w indow s w ith ENERGY STAR certif ied w indow s low ers household energy bills by an average of 12 percent nationw ide. TheEnvironmental Protection Agency performed a cost-effectiveness analysis of Version 6.0 and found it to be cost-effective. That analysis can be foundhere: http://w w w .energystar.gov/sites/default/f iles/ESWDS-Review OfCost_EffectivenessAnalysis.pdf

EPA notes that manufacturers can meet the proposed specif ication for climate zones 5-8 using either double- or triple-pane w indow s. In general, EPA'sdata show that double-pane w indow s that meet the northern climate zone specif ication are cost effective for consumers. Feedback that EPA hasreceived from stakeholders confirms that new glass technologies, improvements in frame performance, and/or better spacer performance can helpmany product lines meet the proposed Northern Zone criteria w ith double-pane w indow s.

Cost Impact: Will increase the cost of constructionThe code change proposal may increase the cost of construction. Given the level of market penetration of ENERGY STAR products, by the time the2018 code is adopted many builders may already be meeting the improved requirements. In some limited cases, builders may incur increased costs. EPAestimates that there is a cost of $20 per w indow to go from the 2009 code requirements to ENERGY STAR Version 6.0. How ever, the U-factorrequirements in the 2015 code are already signif icantly more stringent than the 2009 code requirements, so w e w ould expect the marginal cost perw indow to be less.


http://www.energystar.gov/sites/default/files/ESWDS-ReviewOfCost_EffectivenessAnalysis.pdf

RE36-16Table R402.1.2 [IRC Table N1102.1.2], Table R402.1.4 [IRC Table N1102.1.4]Proponent : Jeremiah Williams ([email protected])



CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 38 13 4/6 13 0 0 0

3 0.350.32 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13

4 except Marine 0.35 0.32 0.55 0.40 49 20 or 13+5 h 8/13 19 10 /13 10, 2 ft 10/13

5 and Marine 4 0.32 0.30 0.55 NR 49 20 or 13+5 h 13/17 30 g 15/19 10, 2 ft 15/19

6 0.32 0.30 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.30 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.32 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.32 0.55 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.30 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.30 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.30 0.55 0.026 0.045 0.057 0.028 0.050 0.055





RE36-16 : TABLE R402.1.2-WILLIAMS12203

Reason: Window eff iciency has been aggressively targeted by programs such as ENERGY STAR because, compared to opaque w alls, w indow sresult in a much higher heat loss. Many Building America projects after 2010 incorporate w indow U-factors as low as 0.27, especially in cold climates,indicating that low -U glazing is f inding w idespread use in the marketplace.1 Given these developments, this code change proposal considers improvingmaximum allow able fenestration U-factors to match older ENERGY STAR specif ications w here data indicate there is substantial market penetration.According to the 2013 ENERGY STAR market assessment conducted by Ducker Worldw ide, the overall ENERGY STAR penetration for residentialw indow s in the year 2013 w as estimated to be 80%.2 For new construction alone, ENERGY STAR residential w indow market penetration ranges from70% to 88% based on climatic region, except for Florida w hich has a low er penetration rate of 36%. This proposed change only affects climate zones 3through 8, for w hich data indicate excellent market penetration. It can thus be concluded that the current residential building market is suff iciently primedfor low ering w indow U-factors in these climate zones. In evaluating the ENERGY STAR 5.0 requirements, it w as found that the climate-zone 4 U-factorof 0.32 w as also cost-effective in climate zone 3, so the proposal includes that level in zone 3.

Energy Savings: DOE conducted an energy analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.3 Analysis of the energy impact of this proposed change found energy savings inclimate zones 3 through 8. Savings ranged from about 0.7% to 1.1% of IECC-regulated end uses (heating, cooling, w ater heating, and lighting).


Bibliography:

1. See Case Studies in the "cold/very cold" regions in the Building America Solution Center at https://basc.pnnl.gov/optimized-climate-solutions/coldvery-cold

2. Available from ENERGY STAR by request3. Taylor, ZT; Mendon, VV; and Fernandez, N. (2015). Methodology for Evaluating Cost-Effectiveness of Residential Energy Code Changes.

Pacif ic Northw est National Laboratory for U.S. Department of Energy; Energy Eff iciency & Renew able Energy. PNNL-21294 Rev1. https://w w w .energycodes.gov/development/residential/methodology.

4. Residential Energy Eff iciency Measures -- Prototype Estimate and Cost Data available athttp://bc3.pnnl.gov/sites/default/f iles/Residential_Report.pdf

Cost Impact: Will increase the cost of construction Data collected by DOE indicates an incremental cost of $0.18/ft2 for a w indow w ith a U-factor of 0.30 compared to a w indow w ith a U-factor of0.35.4 The present analysis conservatively assumes the same incremental cost of $0.18/ft2 for w indow s w ith a U-factor of 0.32 compared to w indow sw ith a U-factor of 0.35.

Cost-effectiveness: DOE conducted a cost-effectiveness analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.4 Assuming w indow s have a useful life of 30 years, an evaluation of the life-cyclecost savings of these improved levels over the 2015 IECC requirements using DOE's cost-effectiveness methodology show s positive life-cycle costsavings in climate zones 3 through 8. Life-cycle savings range from about $57 in zone 3 to $539 in zone 8. The full analysis is available at: https://w w w .energycodes.gov/sites/default/f iles/documents/iecc2018_R-2_analysis_final.pdf.






http://bc3.pnnl.gov/sites/default/files/Residential_Report.pdf



RE37-16 : R402.1.4-FAY12803

RE37-16Table R402.1.4 (IRC Table N1102.1.2)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition



CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

GLAZED

FENESTRATION

SGHC d,e

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.25 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.25 0.030 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.25 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.40 0.026 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 NR 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 NR 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 NR 0.026 0.045 0.057 0.028 0.050 0.055

a. Nonf enestration U-f actors shall be obtained f rom measurement, calculation or an approv ed source.


c. Basement wall U-f actor of 0.360 in warm-humid locations as def ined by Figure R301.1 and Table R301.1.

d. The fenestration U-factor column excludes skylights. The SHGC column applies to all glazed fenestration. Exception: Skylightsmay be excluded from glazed fenestration SHGC requirements in climate zones 1 through 3 where the SHGC for such skylights doesnot exceed 0.30.e. There are no SHGC requirements in the Marine Zone.

Reason: The purpose of this code change is to list the fenestration SHGC requirements in Table R402.1.4 as w ell as Table R402.1.2 (just as the U-factor requirements are listed in both tables). This proposal is simply editorial and w ill ensure that the SHGC requirements are not overlooked w henTable R402.1.4 is used instead of Table R402.1.2 for compliance.

Cost Impact: Will not increase the cost of constructionSince there is no proposed change in requirements, this proposal w ill not affect the cost of the construction.





CLIMATE

ZONE

FENESTRATION

U-FACTOR b

SKYLIGHT b

U-FACTOR

GLAZED

FENESTRATION

SHGC b, e

CEILING

R-VALUE

WOOD

FRAME WALL

R-VALUE

MASS

WALL

R-VALUE i

FLOOR

R-VALUE

BASEMENT c

WALL

R-VALUE

SLAB d

R-VALU

E & DEPTH

CRAWL

SPACE c

WALL

R-VALUE

1 NR 0.75 0.25 30 13 3/4 13 0 0 0

2 0.40 0.65 0.25 3830 13 4/6 13 0 0 0

3 0.35 0.55 0.25 38 20 or 13+5 h 8/13 19 5/13 f 0 5/13



6 0.32 0.55 NR 49 20+5 or 13+10 h 15/20 30 g 15/19 10, 4 ft 15/19

7 and 8 0.32 0.55 NR 49 20+5 or 13+10 h 19/21 38 g 15/19 10, 4 ft 15/19












CLIMATE

ZONE

FENESTRATION

U-FACTOR

SKYLIGHT

U-FACTOR

CEILING

U-FACTOR

FRAME

WALL

U-FACTOR

MASS WALL

U-FACTORb

FLOOR

U-FACTOR

BASEMENT

WALL

U-FACTOR

CRAWL

SPACE WALL

U-FACTOR

1 0.50 0.75 0.035 0.084 0.197 0.064 0.360 0.477

2 0.40 0.65 0.0300.035 0.084 0.165 0.064 0.360 0.477

3 0.35 0.55 0.030 0.060 0.098 0.047 0.091c 0.136

4 except Marine 0.35 0.55 0.0260.030 0.060 0.098 0.047 0.059 0.065

5 and Marine 4 0.32 0.55 0.026 0.060 0.082 0.033 0.050 0.055

6 0.32 0.55 0.026 0.045 0.060 0.033 0.050 0.055

7 and 8 0.32 0.55 0.026 0.045 0.057 0.028 0.050 0.055






R402.1.4 U-factor alternative. An assembly with a U-factor equal to or less than that specified in Table R402.1.4 shall bepermitted as an alternative to the R-value in Table R402.1.2.

Reason: Cost effectiveness of code changes have been ignored at adoption. Thereby resulting in inequity coupled w ith slow adoption. In 2012 theincrease in ceiling insulation from R30 to R38 and R38 to R49 in climate zones 2 and 4 has produced a negative cash f low and a simple payback of 42 to64 years for the consumer. From a cash f low basis, the result raises the monthly mortgage payment, but there is no energy cost savings.The cost dif ference betw een R30 insulation to R38 insulation in climate zone 2 is roughly $420. The energy savings is approximately $10 a year.1 Increasing a $250,000, 20 year mortgage by $420 at 5% interest is approximately $3 per month.2 That's a cost of $36 per year, for $10 a year savings.This results in $26 a year negative cash f low , it w ill take 94 years to recuperate the initial cost and carrying cost just to break even.

Until the 95th year there is no savings.

The cost dif ference betw een R38 insulation to R49 insulation in climate zone 4 is roughly $966. The energy savings is approximately $15 a year.1 Increasing a $250,000, 20 year mortgage by $966 at 5% interest is approximately $6 per month.2 That's a cost of $72 per year, for $15 a year savings.This results in $57 a year negative cash f low , it w ill take 94 years to recuperate the initial cost and carrying cost just to break even.

Until the 50th year there is no savings.

Simple payback results in a 42 to 64 year inequity.

Energy Heel Flat Ceiling1

Climate Zone Representative City Change Energy Savings Incremental Cost Simple Payback

2 Orlando, FL R-38->R-30 $10/y r $420 42 y ears

4 Richmond, VA R-49->R-38 $15/y r $966 64 y ears

Whether w e consider "Simple Payback" or "Cash Flow " the consumer does not see a savings. Savings to the consumer have been misrepresented andhave not low ered their monthly costs, w hile energy savings is negligible.

_______________

The energy modeling was done using the Energy Plus simulation engine and BEopt version 1.4, Cost figures came from ASHRAE RP-1481.


Cost Impact: Will not increase the cost of constructionApproving this proposal w ill reduce the amount of materials needed as w ell as low er the consumers mortgage amount and payments.



RE39-16 : R402.2.1-NORMAN11881

RE39-16R402.2.1 (IRC N1102.2.1)Proponent : Phillip Norman, representing self ([email protected])


R402.2.1 (N1102.2.1) Ceilings with attic spaces Overfill of insulation. Where Section R402.1.2 would require R-38insulation in the ceilingWherever possible, installing R-30 over 100 percent of the ceiling area requiring insulation shall be deemed confined on all sixsides. Insulation fill shall be complete and without voids that could allow air to satisfy the requirement for R-38 wherever the fullheight of uncompressed R-30 insulation extends over the wall top plate at the eaves. Similarly, where Section R402.1.2 wouldrequire R-49 insulation flow in the ceiling, installing R-38 over 100 percent bypass of the ceiling area requiring insulation. Overfillof insulation shall be deemed required to satisfy achieve complete insulation fill. In addition to installation methods that preventvoids within the requirement insulation, the methods shall prevent the presence of air spaces between a barrier film such as thekraft facing of a batt or the containment mesh for R-49 insulation wherever the full height of uncompressed R-38 insulationextends over the blown cellulose, and hard wall top plate at coverings such as drywall.

At the eaves of an attic, insulation installation methods shall achieve as much insulation R-value as possible toward exteriorwall headers. This reduction The eaves shall be packed tight with insulation and overfilled except the resulting R-value at theselocations shall not apply be required to the U-factor alternative approach in Section R402.1.4 and exceed the total UAalternative in Section R402.1.5 R-value required for the adjacent ceiling.

Reason: Edge stapling of kraft facing has been a tragedy, w here millions of homes have convective airf low behind dryw all that w astes energy. Iffacing lacks contact, an opposing unfaced batt surface is likely to also lack contact, forming a convective loop and conduction of energy through thedryw all.Best effort insulation value over exterior w all headers is likely w orse than R30 for an R38 ceiling, and the trades of 2014 found text, e.g. R30everyw here if it can be brought out to the w all headers, is silly. That silly rule might have been tailored to one example of innovative construction w ithraised-heel trusses and deep blow n loose-f ill insulation. A gift of low ered insulation requirement might be rew ard for the truss innovation. With theseunique raised-heel trusses, there seems to be no concern that attic ventilation inlets could be blocked, if not protected w ith baff les. In fact, vent pathprotection should be mentioned if text should address raised-heel trusses. There is no need of the reduced-insulation gift. Higher-density insulation asbatts might boost periphery insulation to the prescribed value, and at the same time control risk of vent fouling.

Cost Impact: Will increase the cost of constructionThe revised section has useful content, requiring more insulation, not less. All insulation circumstances are addressed instead of focus upon excuse ofceiling insulation. Providing required insulation levels and protecting value through airtight shielding against damage w ill add to cost of construction,how ever the intentof code is saving of energy and low ered operating costs for occupants, not enabling cheaper construction.


RE40-16 : R402.2.2-FISCHER13133

RE40-16R402.2.2 (IRC N1102.2.2)Proponent : Mike Fischer, Kellen Company, representing Center for the Polyurethanes Industry of the American Chemistry Council([email protected])


R402.2.2 (N1102.2.2) Ceilings without attic spaces. Where Section R402.1.2 would require R-38 or R-49 insulation levelsabove R-30 in the ceiling and the design of the roof/ceiling assembly does not allow sufficient space for the requiredinsulation, the minimum required insulation for such roof/ceiling assemblies shall be R-30. The full height of uncompressed R-30 insulation shall extend over the top of the wall plate at the eaves. This reduction of insulation from the requirements ofSection R402.1.2 shall be limited to 500 square feet (46 m2) or 20 percent of the total insulated ceiling area, whichever is less.This reduction shall not apply to the U-factor alternative approach in Section R402.1.4 and the total UA alternative in SectionR402.1.5.

Reason: The proposed language relates to the current provision in the IECC-R that allow s for some limited low er R-Values w here the roof/ceilingdesign provides limited space. This might typically apply w here a room addition or a sun room w ith a single slope roof constructed w ith simpledimensional lumber framing instead of trusses. The proposal is largely editorial in that it does not change the insulation requirements, but reorganizes thetext in R402.2.2 to match the format and style used on R402.2.1.The proposal makes one clarif ication that in order to use this option the insulation must extend over the w all top plate to avoid a thermal short circuit.

Cost Impact: Will not increase the cost of constructionThe proposal is an editorial reorganization for clarif ication of current requirements. Thus, the cost of construction is not changed.


RE41-16 : R402.2.2-MCHUGH13168

RE41-16R402.2.2 (IRC N1102.2.2)Proponent : Bill McHugh, The McHugh Company, representing Chicago Roofing Contractors Association


R402.2.2 (N1102.2.2) Ceilings without attic spaces. Where Section R402.1.2 would require insulation levels above R-30 andthe design of the roof/ceiling assembly does not allow sufficient space for the required insulation, the minimum requiredinsulation for such roof/ceiling assemblies shall be R-30. This reduction of insulation from the requirements of Section R402.1.2shall be limited to 500 square feet (46 m2) or 20 percent of the total insulated ceiling area, whichever is less. This reductionshall not apply to the U-factor alternative approach in Section R402.1.4 and the total UA alternative in Section R402.1.5.

Exception: For roof replacement on existing buildings with a roof slope of less than 2 inches in 12 inches, and where the roofcovering is removed and insulation remains, and where the required R-value cannot be provided because of thicknesslimitations presented by existing rooftop conditions such as heating, ventilating and air-conditioning equipment, low door orglazing heights, parapet heights, weep holes, and roof flashing heights not meeting manufacturer's specifications, themaximum thickness of insulation compatible with the available space and existing uses shall be installed. Insulation used shallbe not less than R-3.5 per inch. In areas where flashing is terminated 8 inches or greater above the roof covering including therequired insulation, such insulation shall have an R-value of not less than R-30. For roof slopes less than 2 inches in 12 inches,insulation above the deck shall be not less than R-30. The R-value for roof assemblies with tapered insulation above the deckwith slope greater than 1/8 inch in 12 inches shall be not less than an average of R-30.

Reason: The purpose of this code proposal is to provide guidance to the code user w ho is trying to comply w ith the code but has existing buildingconditions that may preclude compliance. Where codes are practical and reasonable, compliance is increased. This proposal gives a path to complianceto building ow ners and managers, contractors, designers, w ho are faced w ith increased costs – sometimes 20-50% more – w hen having to raisecurbs that hold HVAC units and other rooftop equipment, raise door and w indow sills, replacing w indow s, and plumbing vent stacks, gas and electricalpiping, and many other rooftop equipment service items. This brings common sense to the code through using the f lashing heights as the driver ofinsulation thicknesses for existing buildings.Roofing Flashings are w here a very large percentage of leaks occur. While w e hear exceptions are granted by manufacturers of roofing membranesfor less than 8" f lashing heights at parapets, HVAC units, curbs, w alls, doors and w indow s, the baseline dimension used in legal cases is 8" as statedby The National Roofing Contractors Association (NRCA) Manuals. Plus, most manufacturers 'standard details' are referencing the 8" f lashing heights.The NRCA Manuals have recommended 8" f lashing heights for at least 40 years and hence, it is an industry 'standard'.

Finally, the proposal replaces old less eff icient insulation, usually an R-2.78 to R 4, w ith more eff icient R-5 insulation.

Cost Impact: Will not increase the cost of constructionThis w ill not increase the cost of construction and has the potential to decrease the cost of compliance by not having to rew ork the roof f lashingheights to accommodate insulation thicknesses.


RE42-16 : R402.2.2-MCHUGH13340

RE42-16R402.2.2 (IRC N1102.2.2)Proponent : Bill McHugh, The McHugh Company, representing Chicago Roofing Contractors Association ([email protected])


R402.2.2 (N1102.2.2) Ceilings without attic spaces. Where Section R402.1.2 would require insulation levels above R-30 andthe design of the roof/ceiling assembly does not allow sufficient space for the required insulation, the minimum requiredinsulation for such roof/ceiling assemblies shall be R-30. This reduction of insulation from the requirements of Section R402.1.2shall be limited to 500 square feet (46 m2) or 20 percent of the total insulated ceiling area, whichever is less. This reductionshall not apply to the U-factor alternative approach in Section R402.1.4 and the total UA alternative in Section R402.1.5.

Exception: For roof replacement on existing buildings with a roof slope of less than 2" in 12", and where the roof covering isremoved and insulation remains, and where the required R-value cannot be provided due to thickness limitations presented byexisting rooftop conditions, (including but not limited to heating, ventilating and air-conditioning equipment, low door or glazingheights, parapet heights, weep holes, and roof flashing heights not meeting manufacturer's specifications), the maximumthickness of insulation compatible with the available space and existing uses shall be installed. Insulation used shall beminimum R-5 per inch. In areas where flashing may be terminated a minimum of 8" above the roof covering (including requiredinsulation), insulation shall meet table 401.2.3.

Reason: The purpose of this code proposal is to provide guidance to the code user w ho is trying to comply w ith the code but has existing buildingconditions that may preclude compliance.Where codes are practical and reasonable, compliance is increased. This proposal give a path to compliance to building ow ners and managers w ho arefaced w ith increased costs – sometimes 20-50% more – w hen having to raise curbs that hold HVAC units and other rooftop equipment, door andw indow sills, replacing w indow s, and plumbing vent stacks, gas and electrical piping, and many other rooftop equipment service items.

This brings common sense to the code through using the f lashing heights for the driver of insulation thicknesses for existing buildings. This codeproposal w as approved by the State of Illinois during it's adoption of the 2015 IECC.

Cost Impact: Will not increase the cost of constructionThis w ill not increase the cost of construction and has the potential to decrease the cost of compliance by not having to rew ork the roof f lashingheights to accommodate insulation.


RE43-16 : R402.2.2-MCHUGH13349

RE43-16R402.2.2 (IRC: N1102.2.2)Proponent : Bill McHugh, The McHugh Company, representing Chicago Roofing Contractors Association ([email protected])


R402.2.2 (N1102.2.2) Ceilings without attic spaces. Where Section R402.1.2 would require insulation levels above R-30 andthe design of the roof/ceiling assembly does not allow sufficient space for the required insulation, the minimum requiredinsulation for such roof/ceiling assemblies shall be R-30. This reduction of insulation from the requirements of Section R402.1.2shall be limited to 500 square feet (46 m2) or 20 percent of the total insulated ceiling area, whichever is less. This reductionshall not apply to the U-factor alternative approach in Section R402.1.4 and the total UA alternative in Section R402.1.5.Exception: R-value for roof assemblies with tapered insulation above deck with slope greater than 1/8" in 12" shall average thevalues in Table 401.2.3.

Reason: Low sloped roofs w here there is not enough drainage is a building ow ner and manager's w orst nightmare. Where w ater stands, leaks have aconstant stream of w ater to feed into the building.Tapered insulations have been used for generations to provide slope to drain on existing buildings w here the structural slope cannot be altered.

When using insulation for slope to drain, the code mandated R-Value means meeting minimums very close to drains or scuppers piling huge amounts ofinsulation over the minimums required by Table 402.1.3.

There currently is no credit given for the extra insulation to the building ow ner for adding insulation over and above the code minimum. Using the'average method', allow s the building ow ner to take advantage of the extra insulation at the high points of insulation thickness, to offset the low erinsulation thickness areas.

Cost Impact: Will not increase the cost of constructionThis w ill not increase the cost of construction and has the potential to decrease the cost of compliance by not having to rew ork the roof f lashingheights to accommodate insulation and reduce the total amount of insulation used.


RE44-16 : R402.2.2-NORMAN11882



R402.2.2 (N1102.2.2) Ceilings without attic spaces. Where Section R402.1.2 would require insulation levels above R-30 andthe designSuch spaces, commonly called cathedral ceilings, have depth limited to that of practical roof framing. They are to be craftedwith all of the roof/ceiling assembly does not allow sufficient space seriousness of any other conditioned attic, concerned forroof rot in insulation at temperature below the required dew point where moist air may pass. A solution for insulation, in well-applied closed-cell foam, must be seen as risky in the minimum event of roofing failure. These spaces shall not be violated bycan lights or provisions for attic ventilation and foolish wish to cool composition shingles. There shall be no compromise ofrequired insulation for such roof/ceiling assemblies value. With these provisions, any persisting construction of cathedralceilings shall be R-30. This reduction of insulation from the requirements of Section R402.1.2 shall be limited to 500 square feet(46 m2) or 20 percent of the total insulated ceiling area, whichever with acceptance composition shingle roofing is less. Thisreduction shall not apply to the U-factor alternative approach in Section R402.1.4 and the total UA alternative in SectionR402.1.5 allowed.

Reason: Code shall not be permissive of cheap building of risky structures.

Cost Impact: Will increase the cost of constructionWith the increased cost and the barring of a builder not trained and bearing of expensive, risky, innovative methods, less construction of this kind isintended.


RE45-16 : R402.2.3 (NEW)-WILLIAMS12195

RE45-16R402.2.5 (New) [IRC N1102.2.5 (New)]Proponent : Jeremiah Williams, Department of Energy, representing Self ([email protected])


R402.2.5 (N1102.2.5) Wood frame wall stud spacing. Where Section R402.1.2 and Table R402.1.2 requires 2-inch x 6-inch(38 mm x 140 mm) or larger framing members in exterior above-grade walls, spacing of studs shall be not less than 24 inches(610mm) on-center.

Exceptions:

1. Framing members shall be permitted to be closer than 24 inches (610mm) on-center at doors, windows, walljunctions, and other wall elements where additional framing members is required for structural purposes.

2. Walls in low-rise multifamily residential buildings shall not be required to have 24-inch (610mm) on-center framing.

Reason: This proposal promotes the use of w ider stud spacing w here structurally feasible, to reduce the thermal bridging in exterior w alls, improveenergy eff iciency, reduce w ood resource consumption, and low er builder costs. This technique is often cited as the primary element of systemsreferred to as "advanced framing" or "optimum value engineering."1,2,3 These techniques have been know n and used for many decades and havebecome popular in beyond-code programs, such as Building America, w here thousands of homes have exploited advanced framing concepts for theircost-effectiveness, and have been proven to be structurally sound (in many/most homes) and energy eff icient.4 This proposal w ould encourage theuse of such techniques by requiring that buildings complying via the simple R-value table (R402.1.2) utilize the most common element of advancedframing in w alls that w ould require 2x6 (or larger) framing members to accommodate the required insulation level. Thus, the proposal w ould primarilyimpact homes in colder climates w here improved w all U-factor has the greatest benefit. Where advanced framing techniques cannot be used forstructural reasons, builders w ould have the option of using the U-factor approach (Table R402.1.4), w hich is unchanged by this proposal. Advanced w all framing techniques have been demonstrated and encouraged through DOE's Building America program as w ell as other beyond-code programs for many years. These programs as w ell as industry groups have raised aw areness of the techniques and proved their viability as apreferred approach.5,6

Energy Savings: PNNL conducted an energy analysis of advanced w all framing assuming the framing members are spaced 24 inches on centerinstead of 16 inches on center. The w ider stud spacing results in a low er w all framing fraction of 22% for the 24-inch spacing compared to the 25%w all framing fraction typical of the traditional 16 inch spacing. The corresponding improvement in the w all U-factor results in up to 0.25% energy costsavings of IECC-regulated end-uses (heating, cooling, lighting and w ater heating).


Bibliography:

1. http://w w w .greenbuildingadvisor.com/blogs/dept/musings/pros-and-cons-advanced-framing2. http://buildingscience.com/documents/information-sheets/information-sheet-common-advanced-framing-details3. http://w w w .builderonline.com/building/building-science/5-w ays-to-build-better-homes-for-less-money4. http://apps1.eere.energy.gov/buildings/publications/pdfs/building_america/ba_innovations_1-1-2_advanced_framing.pdf5. http://w w w .homeinnovation.com/~/media/Files/Reports/oveadvancedframingtechniques_techspec.pdf6. http://w w w .builderonline.com/building/building-science/advanced-framing-an-inside-view

Cost Impact: Will not increase the cost of construction Advanced w all framing as defined here involves increasing the spacing betw een the w ooden studs, thus reducing the framing area and as a resultimproving the U-factor of the w all. Because spacing the framing members in such a manner reduces material and labor costs, 24" o.c. w all framing isalw ays expected to be cost-effective w hen it is otherw ise a feasible construction option. When 24" o.c. w all framing is not feasible due to structural orother design constraints, builders may use Section 402.1.4 (U-factor alternative).

Cost-effectiveness: Because advanced framing as defined in this proposal reduces f irst costs and improves energy eff iciency, the proposedchange is cost-effective.



http://www.greenbuildingadvisor.com/blogs/dept/musings/pros-and-cons-advanced-framing

http://buildingscience.com/documents/information-sheets/information-sheet-common-advanced-framing-details

http://www.builderonline.com/building/building-science/5-ways-to-build-better-homes-for-less-money_o

http://apps1.eere.energy.gov/buildings/publications/pdfs/building_america/ba_innovations_1-1-2_advanced_framing.pdf

http://www.homeinnovation.com/~/media/Files/Reports/oveadvancedframingtechniques_techspec.pdf

http://www.builderonline.com/building/building-science/advanced-framing-an-inside-view_o

RE46-16 : R402.2.3-NORMAN11859



R402.2.3 (N1102.2.3) Eave baffle. and insulation provisions For air-permeable insulations in vented atticsWhere needed at soffit vents, a solid baffle durable for service of at least sixty years, shall hold insulation at bay, while allowinga stable maximum amount of insulation to be placed. The airflow resistance of each baffled path shall be installed adjacent tosoffit and eave vents. Baffles shall maintain an opening equal or greater less than the size that of the its screened vent. Thebaffle shall extend over the top of the attic insulation. The baffle Soffit vent paths installed as pre-made "bird block" anddesigned for placement at every frame bay, shall be permitted placed in every frame bay.

For new home construction and in tear-down remodels, eave baffles and at least all eave-edge ceiling insulation shall be placedbefore installation of ceiling-edge drywall, if needed to be any solid material assure thorough insulation, in areas that becomeinaccessible. Where an attic eave extends to a cathedral ceiling or other roof-over-conditioned spaces, do not employ theinsulated cathedral ceiling cavity as passage to admit air for attic venting.

Reason: The revision deals w ith all insulation and attic vent deficiencies at low eaves. A maximum of insulation must be placed thoroughly at poorly-accessible or inaccessible eaves. Strong batt insulation is needed, fully f illing available space, if not meeting requirements of general ceiling R-value. Allof this is related to rigor in placement of insulation baff les. It is good to suggest to contractors that eaves be treated from below before eave-edgedryw all is placed. In this w ay, baff les are not dif f icult or w asteful of insulation value, and w here in general every roof bay should be vented, that w orkis not onerous.

Cost Impact: Will increase the cost of constructionCost w ill go up in part from installing more soff it vents, and baff ling to protect them againt blockage by insulation. The additional vents are verynecessary w ith US home construction methods. They are required by IRC Section R806, Roof Ventilation, and providing them to meet code isunavoidable additional cost.


RE47-16R402.2.3 (IRC N1102.2.3), R402.2.4 (IRC N1102.2.4), Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])

2015 International Energy Conservation CodeDelete without substitution:

R402.2.3 (N1102.4.2.3) Eave baffle. For air-permeable insulations in vented attics, a baffle shall be installed adjacent to soffitand eave vents. Baffles shall maintain an opening equal or greater than the size of the vent. The baffle shall extend over the topof the attic insulation. The baffle shall be permitted to be any solid material.


R402.2.4 (N1102.2.4) Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such asattics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surroundingsurfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed orequivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to preventthe loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means ofmaintaining the installed R-value of the loose-fill insulation.

Exception: Vertical doors that provide access from conditioned to unconditioned spaces shall be permitted to meet thefenestration requirements of Table R402.1.2 based on the applicable climate zone specified in Chapter 3.

Revise as follows:

TABLE R402.4.1.1 (N1102.4.1.1)AIR BARRIER AND INSULATION INSTALLATION







material.

Ceiling/attic



sealed.

Access openings, drop down stairs or knee wall doors to

unconditioned attic spaces shall be sealed.



Access openings, drop down stair, or knee wall door attic

hatch access panels, shall be insulated to the same lev el

as the assembly they are penetrating through.

Access to all equipment located in insulated attics shall be

prov ided that prev ents damaging or compressing the

installed insulation.

An insulation dam shall be prov ided in order to prev ent

loose-f ill insulation f rom spilling into the liv ing space and to

prov ide a permanent means of maintaining the installed R-

v alue of the loose f ill at the access or other locations in

the attic.

For air-permeable insulations in v ented attics, a baf f le

shall be installed adjacent to sof f it and eav e v ents and

maintain an opening greater than or equal to the net f ree

area of the sof f it v ent. The baf f le shall extend f rom the

sof f it v ent ov er the top of the attic insulation and

suf f icient space shall be maintained so insulation will cov er

the top plate. The baf f le shall be any solid air barrier

material.





Walls The junction of the top plate and the top of exterior walls shall

be sealed.












insulation.














Narrow cav ities





conditioned spaces.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Section R402.2.3 and R402.2.4 in the prescriptive path of the code describe aspects of insulating installation criteria that should be mandatoryfor all pathw ays of the energy code. The criteria ensure that R-value of the installed material is maintained and specif ically addresses installation issuesthat w ill not affect the ability of a Builder to gain greater f lexibility through utilization of performance paths in the code.


RE47-16 : R402.2.3-SCHWARZ12733

Cost Impact: Will increase the cost of constructionThe majority of the country is still utilizing the prescriptive path for code compliance so there w ill be no or little cost implications associated w ith theadoption of this proposal. Rather this proposal w ill ensure that proper installation techniques are maintained regardless of the path that is chosen.


RE48-16 : R402.2.4-GIESZLER10916

RE48-16R402.2.4 (IRC N1102.2.4)Proponent : Michael Gieszler, representing Oregon Building Officials Association ([email protected])

2015 International Energy Conservation CodeR402.2.4 (N1102.2.4) Access hatches and doors. Access doors and access panels from conditioned spaces tounconditioned spaces such as for access to attics and crawl spaces, shall be weatherstripped and insulated to a levelequivalent to the insulation on the surrounding surfaces. Access A permanent baffle that is, or is at least structurallyequivalent to, plywood shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framedor equivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is aroundaccess openings to prevent the loose-fill loose fill insulation from spilling out into the living space when the attic opening. Thepath of travel from an access is opened, and opening to provide a permanent means serviceable equipment shall be designedto prevent damage or compression of maintaining the installed R-value of the loose-fill building thermal envelope insulation.


Reason: Rew orded for clarity. The reference to access doors limits the applicability of this section to doors and needs to be removed to make it clearthe requirements apply to hatches as w ell. Baff les made of plastic, metal or other material may be suff icient but are not necessarily structurallyequivalent to w ood framing. This change w ill allow greater design f lexibility w hile maintaining the performance desired.

Cost Impact: Will not increase the cost of constructionAllow ing a baff le material that is not needed to be structurally equivalent to "w ood framing" (some people might interpret that to mean 2x material) butw ith enough structural integrity to hold back insulation, w ill low er construction costs.


RE49-16R402.2.4 (IRC N1102.2.4)Proponent : Phillip Norman ([email protected])

2015 International Energy Conservation CodeDelete and substitute as follows:

R402.2.4 (N1102.2.4) Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such asattics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surroundingsurfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed orequivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to preventthe loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means ofmaintaining the installed R-value of the loose-fill insulation.


Hinged doors and lift portals from conditioned spaces to unconditioned spaces such as attics, unconditioned basements andcrawl spaces, shall be insulated to the Energy Star standards of exterior opaque swinging doors, and shall be air sealedwith well-fitting gaskets. The portal frame shall be sealed air tight in its rough opening.

The entry to an attic space at a portal shall have a surround of an ample raised floor that does not diminish insulation value.Flooring shall protect insulation against trampling while giving safe passage, to all attic electrical service points including fans,lights and junction boxes. Junction boxes not accessible from heated space shall be raised above insulation and flooring levels,or where this has failed, shall be flagged as a decked service point. Accessible service points shall include static vents thatrequire periodic cleaning. Where a service point is buried in insulation, insulation over the service point shall be in batt form andtolerant of displacement for accessing the service point.

Reason: This standard is that already stated for vertical hinged doors as hatches. There is economy and clarif ication in a common standard forhatches that face the same thermal challenge, less than that of an exterior door. Let hatches have the realistic and achievable Energy Star non-zeroairtightness requirement. At the same time, raise insulation standards for all hatches to a single Energy Star number, rather than an array in found TableR402.1.2.The higher insulation standard is U

The Energy Star sealing requirement is a multiple of door area, not zero and easily achievable. Leakage <= 0.5 cfm/ft2.

Weatherization has value mainly w here it serves undiminished, in perpetuity. Methods and materials shall be crafted for sixty year minimum service.

CONTENDING WITH HYPEBetter rules shall at last counter false statements such as this of 1999, passed along by Habitat for Humanity, as w ritten by southface.org: Don't leavea hole in the ceiling : A ¼-inch gap around the perimeter of a standard pulldown staircase can potentially leak the same amount of air that issupplied by a typical bedroom heating duct (~100 CFM). Unsealed, the attic access in a home leaks energy dollars and causes the house to be lesscomfortable. During winter, conditioned room air may escape to the ventilated attic, while in the summer, hot attic air (which may contain airborneinsulation fibers) can infiltrate into the home.

The potential leakage at an attic ladder is overstated here, times f ive. Follow ing the hole hype, there is surrender to impractical insulation schemes.

One w ay to counter the hype and move on to practical rules, products and methods, is in full demonstration of reality w ith math of heat transfer andleakage. I offer this applied math in w eb resource Insulation Math. Simple numbers are offered for common parameters: a home w ith 4400 65°HDD, agas furnace 88% eff icient, and energy at $2 per therm. Methods are simplif ied.

There is little money to be saved in extreme treatment of a small area in a home.DISCUSSION OF ATTIC LADDER INSULATIONConsider a drop-dow n attic ladder 22.5" x 54", door area, 8.4 sq ft.

PanelThickness Ref f Sy stem

R

U

(1/Sy stemR)

AnnualHeatCost

1/4" DoorPanel orBareCeiling

0 3 0.33 $6.60

1" 1.8 5 0.2 $4.03

1.25" 2.4 5.6 0.18 $3.60

1.5" 3.0 6.3 0.16 $3.20

2" 4.2 7.4 0.13 $2.72

3" 6.2 9.4 0.11 $2.14

R38Ceiling 38 41 $0.49

R49Ceiling 49 52 $0.39

Not more than $1 per year is gained or given, w ithin the range of practical options for an insulated door panel. Just aim dow n the middle, and be done.Make an achievable choice, that people w ill happily accept.

DISCUSSION OF ATTIC LADDER AIR LEAKAGEConsider a drop-dow n attic ladder 22.5" x 54", door area, 8.4 sq ft.

Av g. Gap

in

Path Area

sq in

Qnat

cf m

Leakage Cost

Dollars Per Year

Conv ection Cost

Dollars Per Year


http://www.habitat.org/lc/env/pdf/Attic_Access.pdf

https://sites.google.com/site/phillipnormanatticaccess/Home/insulation-math

RE49-16 : R402.2.4-NORMAN9945

0.01 1.5 1 $1 $7

0.06 9.1 5 $7 $7

0.12 18.2 9 $14 $7

0.25 38 20 $29 $7

This considers only the gap betw een the door and the ladder frame, likely less than 0.06" on average in any not-decrepit ladder even w ithout gaskets.Conceivable leakage cost is comparable to cost of energy convection through the door.

In addition, consider gaps betw een the ladder frame and its rough opening. A 1/8" average gap is common here, w here molding against a rough ceilingmay only hide the problem from view . Plaster or caulk these gaps to easily save $14 per year or more. Know that a ladder cover in response to thehype, is useless as a seal of leakage outside the ladder frame, in addition to not sealing leakage at the ladder door.

Possible leakage of up to 20 cfm is one quarter the f low of a good bath fan, and little compared to 100 cfm hype.

DISCUSSION OF LIFT_PLUG ATTIC PORTALS OR SWINGING DOORSThese w ill be smaller than drop-dow n access ladders, w ith less potential to save energy. Apply the same Insulation Math.

Consider example size 22" x 30", 4.6 sq ft:.

Product U System R Annual Heat Cost Cost Difference vs. New Requirement

Drywall Plunker 3 $3.68 -$1.81

New Requirement 0.17 5.9 $1.87 Reference

R49 Ceiling 52 $0.21 $1.66

Handling safety and durability of a modest plug, U = 0.17, far outw eigh $1.50 energy savings potential of a clumsy, thick plug costing perhaps $100more.

Bibliography: https://sites.google.com/site/phillipnormanatticaccess/Home/insulation-mathhttps://sites.google.com/a/r5portals.com/w w w /better-building-codes-for-access-portals

Cost Impact: Will not increase the cost of constructionA durable, modestly-insulated service hatch, factory made and sold in large quantities, has low er installed cost than a dryw alled, fragile custom plunkerw ith useless afterthought insulation gob. Modestly-insulated and sealed service hatches are a necessary cost in home construction and refurbishment.There is littleopportunity to save energy w ith hatch insulation, plus or minus one dollar per year from the median new standard. Sealing, w hich mightsave more than insulation, is part of existing code. There is much opportunity to use safe access to good advantage, thoroughly taking care of energyeff iciency and achieving needed usefulness in spaces accessed. Investment in a really-functional hatch, as in a strong and amply-sizes drop-dow nladder may be necessary in the accomplishments, as in permitting the carry of large bags of insulation and long, large sections of lumber, for w hich aplunker access over a closet shelf is useless.There is more to access than a hole. We must see opportunity in the investments of good f ixed lightingand decking, saving far more than the cost of the good ladder. Most energy-savings w ith easy return w ill be found in our attics. Savings opportunitiesaccessed include achievement of required air sealing of home ceilings. Promised energy independence and large savings w ith LED lighting w ill mainlybe delivered through attic spaces. Adding insulation is usually a minor opportunity, to be taken only after all others. Where opportunities are w rung outof our attics, it is like f inding pots of gold. Attic spaces are never to be treated as trash heaps. Thorough and lasting w eatherization is serious business,not to be neglected.




https://sites.google.com/a/r5portals.com/www/better-building-codes-for-access-portals

RE50-16 : R402.2.4-RODRIGUEZ12855

RE50-16R402.2.4 (IRC N1102.1.4)Proponent : Cesar Rodriguez, representing Metro Atlanta Inspectors Association ([email protected])

2015 International Energy Conservation CodeR402.2.4 (N1102.2.4) Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such asattics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surroundingsurfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed orequivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to preventthe loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means ofmaintaining the installed R-value of the loose-fill insulation.

Exception Exceptions: Vertical doors that provide access from conditioned to unconditioned spaces shall be permittedto meet the fenestration requirements of Table R402.1.2 based on the applicable climate zone specified in Chapter 3.

1. Vertical doors providing access from conditioned to unconditioned spaces that comply with the fenestrationrequirements of Table R402.1.2 for the applicable climate zone specified in Chapter 3 shall not be required tocomply with this section.

2. Horizontal pull-down stair-type access hatches in ceiling assemblies that provide access from conditioned tounconditioned spaces shall not be required to comply with this section provided that such hatches have anaverage maximum U-Factor of U-0.10 or an R-value of not less than R-10, have not less than 75% of thepanel area having insulation of an R-value of not less than R-10, have a net area of the framed opening notexceeding 13.5 square feet and have the perimeter of the hatch edge weather stripped. This exception shallnot apply where the U-factor alternative in Section R402.1.4 and the total UA alternative in Section R402.1.5are used.

Reason: It has been our experience that the added insulation requirement in Section N1102.2.4 is frequently achieved w ith f ield crafted detachableapparatuses. Unfortunately, over time these are commonly discarded or w orse, set aside compressing adjacent ceiling insulation thus defeating theintended benefit. The objective of this proposal is to address this f ield modif ication issue and provide for a more permanent installed solution.

During the 2015 ICC code development cycle for the IRC and the IECC an exception w as added to the ceiling insulation requirements for vertical doorsproviding access to attic areas in IRC Section N1102.2.4 and IECC Section R402.2.4. This exception w as based on the premise that vertical attic accessdoors betw een conditioned and unconditioned spaces can be treated as fenestration. Horizontally positioned attic access hatches are a similar issue. These horizontal hatches are being required to have insulation levels that match the surrounding ceiling w hich is signif icantly more stringent thanskylight fenestration products located in these same ceiling assemblies.

For example, in Table N1102.1.2 (R402.1.2) Skylights are required to meet a U-factor that ranges from 0.75 in Climate Zone 1 to 0.55 in Climate Zone 8. Inaddition, Section N1102.3.3 (R402.3.3) allow s up to 15 square feet of the fenestration per dw elling unit (w hich includes skylights) to be exempt from therequirements in Table N1102.1.2 (402.1.2). It does not make sense to require R-30 to R-49 insulation for a pull dow n stair type access hatch in aninsulated ceiling w hen one can have a skylight up to 15 square feet in area that is exempt from the envelope requirements or that has a U-FACTOR of0.55-0.75 (less than R-2). Insulating pull dow n stair access hatches to the levels specif ied in N1102.2.4 (R402.2.4), compared to the skylightsinsulation requirements is expensive, and in many cases not practical.

In addition, affordable, pre-manufactured pull dow n stair access systems are not readily available to meet the R-30 to R-49 target. As a result, f ieldcustomization of access hatches is sometimes employed to achieve these performance levels. Inspection and verif ication for compliance becomes achallenge. As noted previously long term system performance of these f ield customized entry devices may also vary. Commonly the f ield crafteddetachable apparatuses are designed to be removed for attic access and placed on the adjacent attic joists. This results in the insulation beingcompressed thus reducing its effectiveness. Also providing suff icient air sealing around the hatch that remains durable long term is dif f icult. Finally,removal of the insulated covers for access may present a safety hazard to service personnel, inspectors and building ow ners having to stand onladders w hile removing the hatches.

Quality standardized manufactured pull dow n stair systems how ever provide a safer, permanent access w ith proven performance for the life of thestructure. Factory built energy rated access systems provide consistent air sealing performance and ensure consistent energy performance w hilehelping to maintain air quality through reduced air inf iltration.

This proposal provides a solution by permitting a reasonable reduction in the insulation values for pull dow n stair access hatches that are less than orequal to 13.5 square feet (approximately 30" X 64") in attic ceilings. This maximum size accommodates most manufactured products available. The U-value specif ied at U-0.10 is less stringent than the U-values specif ied for the insulated ceilings but is far more stringent than those permitted forskylights in all Climate Zones. Too the size limit is more stringent than that permitted for skylights w hich can have one unit up to 15 square feet in sizeexempted from the code requirements w hile all other skylights are less stringent than the pull dow n stair assembly proposed. Finally, the proposal alsodoes not allow this reduction to be factored into the U-Factor alternative calculation procedure in N1102.1.4 (R402.1.4) or the total UA alternativeprocedure in N1102.1.5 (R402.1.5). This is consistent w ith the limitations in Section N1102.2.1 (R402.2.1) for ceilings w ith attic spaces and in SectionN1102.3.3 (R402.3.3) for skylights.

Cost Impact: Will not increase the cost of constructionThe reduced cost of f ield installed apparatuses and insulation w ill offset the cost of the pull-dow n stair.


RE51-16 : R402.2.5-HUNTER12424

RE51-16R402.2.5 (IRC N1102.2.5)Proponent : Matthew Hunter ([email protected]); Loren Ross, representing American Wood Council ([email protected])


R402.2.5 Mass walls. Mass walls for the purposes of this chapter shall be considered above-grade walls of concrete block,concrete, insulated concrete form (ICF), masonry cavity, brick (other than brick veneer), earth (adobe, compressed earth block,rammed earth) and heavy timber (solid timber/ , cross-laminated timber, logs), or any other walls having a heat capacity greaterthan or equal to 6 Btu/ft2 × °F (123 kJ/m2 × K).

Reason: Cross-laminated timber (CLT) is a new technology developed in Europe that consists of smaller w ood pieces factory glued together to makethick w ood sections. It is analogous to large section members currently associated w ith heavy timber in the current code. In fact, the 2015 IBC alreadyrecognizes CLT as heavy timber construction. This proposal adds CLT to the list of mass w alls and groups solid timber, CLT, and logs in the moregeneral category of heavy timber to be consistent w ith the rest of this section.

Cost Impact: Will not increase the cost of constructionThis proposal only adds clarity to how CLT should be consider in the residential energy code. No cost increase is anticipated w ith this code change.


RE52-16 : R402.2.5-VANGEEM10454

RE52-16R402.2.5 (N1102.2.5)Proponent : Martha VanGeem, self, representing Masonry Alliance for Codes and Standards; Theresa Weston, representing DuPontBuilding Innovations ([email protected]); Emily Lorenz, self, representing self ([email protected])

2015 International Energy Conservation CodeR402.2.5 (N1102.2.5) Mass walls. Mass walls for the purposes of this chapter shall be considered above-grade wallscomplying with one of the following:1. Constructed of concrete block, concrete, insulated concrete form (ICF), masonry cavity, brick (other than brick veneer), earth(adobe, compressed earth block, rammed earth) and solid timber/logs, or any other walls having .2. Weighing not less than 35 psf of wall surface area.3. Weighing not less than 25 psf of wall surface area where the material weight is not more than 120 pcf. 4. Having a heat capacity greater than or equal to 6 exceeding 7 Btu/ft22 × °F.5. Having a heat capacity exceeding 5 Btu/ft2 × °F (123 kJ/m2 × K) where the material weight is not more than 120 pcf.

Reason: The energy-saving benefits of thermal mass are not based on the w eight of the w all or the heat capacity, but on the thermal dif fusivity of thematerials. It is thermal dif fusivity or its components of thermal conductivity, specif ic heat, and density that are entered into simulation softw are to modelthermal mass. A simplif ication of this to ease code compliance is to list the w all types as currently is done.This proposal corrects the heat capacity requirement to be based on w eight, w hich is more technically correct, and to align it w ith w hat is in the IECCcommercial. Items 2 through 5 match w hat is in the IECC commercial w hile still maintaining the simplif ied listing of w alls in Item 1.

A paper providing more information has been published on this subject and is available upon request: VanGeem, M.G., "Optimal Thermal Mass and R-Value in Concrete," First International Conference on Concrete Sustainability, Tokyo, May 2013.

Cost Impact: Will not increase the cost of constructionThis proposal simply corrects heat capacity requirements to make them more technically correct and align them w ith w aht is already in IECC commercial.There is no change in the code requirements that w ould impact the cost of construction.


RE53-16Table R402.2.6 (IRC Table N1102.2.6)Proponent : Mark Nowak, representing Steel Framing Alliance ([email protected])


TABLE R402.2.6 (N1102.2.6)STEEL-FRAME CEILING, WALL AND FLOOR INSULATION (R-VALUE)

WOOD FRAME

R-VALUE

REQUIREMENT

COLD-FORMED STEEL

EQUIVALENT R-VALUEa

Steel Truss Ceilingsb

R-30 R-38 or R-30 + 3 or R-26 + 5

R-38 R-49 or R-38 + 3

R-49 R-38 + 5

Steel Joist Ceilingsb

R-30 R-38 in 2 × 4 or 2 × 6 or 2 × 8 R-49 in any f raming

R-38 R-49 in 2 × 4 or 2 × 6 or 2 × 8 or 2 × 10

Steel-Framed Wall, 16″ on center

R-13 R-13 + 4.2 or R-19 + 2.1 or R-21 + 2.8 or R-0 + 9.3 or R-15 + 3.8 or R-2119+ 3.1

R-13 + 3 R-0 + 11.2 or R-13 + 6.1 or R-15 + 5.7 or R-19 + 5.0 or R-21 + 4.7


R-20 + 5 R-13 + 12.7 or R-15 + 12.3 or R-19 + 11.6 or R-21 + 11.3 or R-25 + 10.9


Steel Framed Wall, 24″ on center

R-13 R-0 + 9.3 or R-13 + 3.0 or R-15 + 2.4

R-13 + 3 R-0 + 11.2 or R-13 + 4.9 or R-15 + 4.3 or R-19 + 3.5 or R-21 + 3.1

R-20 R-0 + 14.0 or R-13 + 7.7 or R-15 + 7.1 or R-19 + 6.3 or R-21 + 5.9

R-20 + 5 R-13 + 11.5 or R-15 + 10.9 or R-19 + 10.1 or R-21 + 9.7 or R-25 + 9.1


Steel Joist Floor

R-13 R-19 in 2 × 6, or R-19 + 6 in 2 × 8 or 2 × 10

R-19 R-19 + 6 in 2 × 6, or R-19 + 12 in 2 × 8 or 2 × 10

a Cav ity insulation R- v alue is listed f irst, f ollowed by continuous insulation R- v alue.


RE53-16 : TABLE R402.2.6-NOWAK12269

b. Insulation exceeding the height of the f raming shall cov er the f raming.

Reason: This proposal corrects an inconsistency in the code by eliminating tw o conflicting entries in the code for R21 insulation on a steel w all w henusing the table that establishes equivalency w ith a w ood stud w all w ith R-13+0 insulation. Public comment number 1 to E66-09/10 w as mistakenlysubmitted w ith this error and subsequently approved.

Cost Impact: Will increase the cost of constructionAn additional R-1 of continuous insulation w ill be required under this proposal if a designer selects R-19 cavity insulation. The extra cost could beoffset by a low er continuous insulation value for R-21 cavity insulation for these assemblies. Unfortunately, this is necessary to address an error in thepublic comment that w as approved w ith EC66-09/10.


RE54-16 : R402.2.7-CRANDELL12872

RE54-16R402.2.7 (IRC N1102.2.7)Proponent : Jay Crandell, P.E., ARES Consulting, representing Foam Sheathing Committee of the American Chemistry Council


R402.2.7 (N1102.2.7) Walls with partial structural sheathing. Where Section R402.1.2 would require continuous insulationon exterior walls and structural sheathing covers 40 percent or less of the gross area of all exterior walls, the continuousinsulation R-value shall be permitted to be reduced by an amount necessary to result in a consistent total sheathing thickness,but not more than R-3, on areas of the walls covered by structural sheathing. This reduction shall not apply to the U-factoralternative approach in Section R402.1.4 and the total UA alternative in Section R402.1.5. Where, in accordance with thissection, the R-value of exterior continuous insulation is reduced, the portion of wall with reduced R-value for exterior continuousinsulation shall remain compliant with Section R402.1.1.

Reason: These provisions, for practical reasons, permit the reduction in thickness or R-value of continuous insulation over intermittent brace panels toprovide a means of maintaining a uniform w all thickness. How ever, the reduced R-value of continuous insulation can result in a non-obvious conflictw ith the w ater vapor control provisions in the building code depending on climate zone, particularly the selection of an appropriate vapor retarder andverif ication that a compatible amount of continuous insulation is still retained to control w ater vapor (i.e., keep the w all and structural sheathingsuff iciently above the dew point temperature to prevent potential condensation problems as intended by the building code). In cold climates, providing asuff icient amount of exterior insulation to keep w alls "w arm" is important for the same reason that ensuring exterior structural sheathing and w ater-resitive barrier materials on "cold" w alls w ithout exterior insulation are suff iciently vapor permeable (relative to the permeance of the selected interiorvapor retarder) to prevent unacceptable moisture accumulation.

Cost Impact: Will not increase the cost of constructionThis proposal ensures code compliance and coordination of I-Codes, changes no requirement in the code, and has no cost impact (although it may helpprevent unintended or inadvertent long-term cost impacts).


RE55-16 : R402.2.14 (NEW)-URSENBACH13277

RE55-16R402.2.14 (New) [IRC N1102.2.14 (New)], R402.3.6 (New) [IRC N1102.3.6 (New)]Proponent : Brent Ursenbach, Salt Lake County, representing Utah Chapter ICC ([email protected])


R402.2.14 (N1102.2.14) Accessory building insulation. Detached and attached accessory structures and rooms, enclosingconditioned space shall meet the insulation requirements of this code.

Exceptions: For structures with thermal isolation, and enclosing conditioned space, the following reductions to the insulationrequirements of this code shall apply:

1. The ceiling insulation R-Values shall be not less than R-19 in climate zones 1 through 4, and R-30 in climate zones 5through 8.

2. The wall insulation R-value shall be not less than R-13 in climate zones 1 through 4, and not less than R-15 in climatezone 5 through 8. Walls separating an accessory room with thermal isolation from a conditioned space shall meet thebuilding thermal envelope requirements of this code.

3. The slab-on-grade perimeter insulation R-value shall be not less than R-5 for climate zones 5 through 8.

R402.3.6 (N1102.3.6) Accessory building fenestration. Detached and attached accessory structures and rooms enclosingconditioned space shall meet the fenestration requirements of this code.

Exception: For structures with thermal isolation, and enclosing conditioned space, the following increases to thefenestration requirements of this code shall apply:

1. The fenestration U-factor shall not exceed 0.40 in Climate Zones 2 through 4, and 0.35 in Climate Zones 5 through8. New fenestration separating the accessory room or space from a conditioned space shall meet the buildingthermal envelope requirements of this code.

2. The skylight U-factor shall not exceed 0.60 for all climate zones.

2. Roll-up garage doors shall have insulation of a R-value of not less R-10 installed within each sectional panel.

3. Roll-up garage doors shall include weatherstripping along all edges and seams.

Reason: The reasoning used w ith the sunroom exceptions (R402.2.13 and R402.3.5) is that these rooms are not continuously conditioned, or if theyare, to a reduced set point. A similar consideration should be given to accessory structures and rooms. In many regions, intermittent conditioning ofattached garages and shops, as w ell as detached garages, sheds, shops and playhouses is a common occurrence, more common than conditionedsunrooms. Please note that for this proposal, the R-values are higher and U-factors are low er than those allow ed in the sunroom exceptions. As the code is currently w ritten, it is virtually impossible to achieved full compliance in garages as NFRC 100-rated overhead doors do not exist.Contractors and homeow ners too often simply add conditioning to these structures after the projects are completed. Providing an w orkable exceptionw ill increase energy eff iciency, rather than having these structure not insulated at all and then conditioned after the fact.

Cost Impact: Will not increase the cost of constructionThis proposal w ill not increase the cost of construction as the current full requirements in the IECC are more stringent than the requirements defined inthis code change.


RE56-16R402.4 (IRC N1102.4), R402.4.1.2 (IRC N1102.4.1.2), R402.4.1.2.1 (New) [IRC N1102.4.1.2.1 (New],R402.4.1.2.1.1 (New) [IRC N1102.4.1.2.1.1 (New)], R402.4.6 [IRC N1102.4.6) (New)]Proponent : Sean Maxwell, representing self ([email protected])


R402.4 (N1102.4) Air leakage (Mandatory). The building thermal envelope shall be constructed to limit air leakage inaccordance with the requirements of Sections R402.4.1 through R402.4.5 R402.4.6.

R402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones 3 through 8.Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written report of theresults of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performedat any time after creation of all penetrations of the building thermal envelopebuilding thermal envelope.

During testing:




Where required by the code official, testing shall be conducted by an approved third party.

A written report of the results of the test shall be provided to the code official. The written report shall include:

1. The name and place of the business of the party conducting the test.2. The address of the building which was tested.3. The floor area of the conditioned space of the dwelling unit. 4. The measured air leakage rate of each testing unit.5. The date or dates of the test.6. A certification by the party conducting the test, indicating the accuracy of the test results.7. The signature of the party who conducted the test.


R402.4.1.2.1 (N1102.4.1.2.1) Alternative testing procedure for buildings with two or more dwelling units within thebuilding thermal envelope. Where two or more dwelling units are located within a building thermal envelope, the followingprocedure shall be an alternative to testing in accordance Section R402.4.1.2:

For purposes of testing, the following spaces and areas are defined:

1. Each dwelling unit including each occupiable conditioned space other than a dwelling unit within the building thermalenvelope shall be considered a testing unit.

2. The enclosure surface area of a testing unit shall be the sum of the areas of all of the following:1. Each exterior wall of the testing unit2. Each interior wall of the testing unit that abuts another testing unit or units, 3. Each ceiling of the testing unit that abuts another testing unit or units, or abuts unconditioned space.4. Each floor in the testing unit that abuts another testing unit or units, or abuts unconditioned space.

3. The conditioned-space floor area of a dwelling unit shall be calculated in accordance with BOMA Z65.1 or BOMA Z765.1, asapplicable. Where either of these standards exclude floor areas having a ceiling height of less than 5 feet (1524 mm), such floorareas shall be included in the calculation of conditioned-space floor area.

Each testing unit shall be tested to verify that the air leakage rate does not exceed 0.3 cubic feet per minute per square foot ofthe enclosure surface area of the testing unit. Testing shall be conducted in accordance with ASTM E779 or ASTM E1827using a blower door. Test results shall be reported at a pressure of 0.2 inches w.g. (50 Pascals). Testing shall be performed atany time after creation of all penetrations of the building thermal envelope. During testing:

1. Exterior windows and doors, fireplace and stove doors shall be closed, but not sealed, beyond the intendedweather-stripping or other infiltration control measures.

2. Dampers including exhaust, intake, makeup air, backdraft and flue dampers shall be closed, but not sealed beyondintended infiltration control measures.



Where required by the code official, testing shall be conducted by an approved third party.

A written report of the results of the test shall be prepared and provided to the code official. The report shall include all of thefollowing:

1. The name and place of the business of the party conducting the test.2. The address of the building and dwelling unit numbers which were tested.3. The conditioned-space floor area of each testing unit. 4. The air leakage rate at 0.2 inches w.g. (50 Pascals) of each testing unit.5. The date or dates of the testing.6. A certification by the party conducting the tests which indicates the accuracy of the test results.7. The signature of the party who conducted the tests.

R402.4.1.2.1.1 (N1102.4.1.2.1.1) Alternative testing procedure for buildings with more than seven dwelling units. Where there are more than seven dwelling units within a building thermal envelope, and where approved by the code official, thefollowing shall be an alternative to the testing of all dwelling units in accordance Section R402.4.1.2.1:

1. Sample sets of not more than seven testing units shall be determined. Each sample set shall include one ormore occupiable common conditioned space, other than dwelling units. Each sample set shall be representative ofall types of dwelling units and occupiable common conditioned spaces other than dwelling units, within the buildingthermal envelope.

2. All testing units in the first sample set shall be tested to verify that the air leakage rate does not exceed 0.3 cubicfeet per minute per square foot of enclosure surface area of the testing unit, Where all testing units of the firstsample set tested do not exceed the leakage rate maximum, only one testing unit of each sample set testedthereafter shall be required to be tested. Where any subsequent test exceeds the air leakage ratemaximum, additional testing shall be required in accordance with the following procedure:

2.1. Two additional testing units in the same sample set shall be tested. Where either of those additionaltesting units fail to comply, the remaining untested testing units in the sample set shall be tested. Fortesting of the next sample set, all of the testing units in the set shall be tested.

2.2. Where all of testing units of the next sample set tested do not exceed the leakage rate maximum, andwhere the code official approves a reduction in the number of units to be tested in future sample settesting, the testing procedure shall reset to that in Item 2.

R402.4.6 Dwelling unit and townhouse separation walls (Mandatory). Separation walls and ceilings between two or moredwelling units or between townhouses, all within a building thermal envelope, shall be air-sealed in accordance with SectionR402.4.

Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ANSI/BOMA Z65.1-1996 Office Buildings: Standard Methods of MeasurementANSI/BOMA Z765.1-2003 Square Footage Method for Calculating.Reason: The 2015 International Energy Conservation Code calls for all buildings or dw elling units to be verif ied w ith a blow er door as having an airleakage rate not exceeding 3 air changes per hour at 50 Pascals; how ever, because of the unique challenges of testing multifamily buildings, somemodif ication to the language is necessary. Without it, there are few er practical w ays to enforce this code requirement for multifamily buildings. What isproposed here is a modif ication that w ould call for a specif ic form of testing for multifamily buildings that is easily enforced and w ould advance thebuilding industry in valuable w ays.New York State recently adopted the residential portions of the 2015 IECC, and it has considered some modif ications to allow compartmentalizationtesting of apartments, a method described below . It is more cost-effective, more easily implemented on a w ide basis, and achieves many other benefitsfor building ow ners and occupants that other test methods do not. For this reason, this test method called for in many other guidelines such as ASHRAE62.2-2013, LEED BD+C: Multifamily Midrise, New York State's Multifamily Performance Program, and the EPA's ENERGY STAR® Multifamily High Riseprogram.

New York State published is proposed 2015 Supplement to the New York State Energy Conservation Construction Code, containing its recommendedchanges to the blow er door test requirements. We recommend similar language be adopted by the IECC.

http://w w w .dos.ny.gov/DCEA/pdf/2015EnergyCodeSupplementdraft20151106.pdf.

Testing Methods

There are several valid w ays to test a multifamily building's air leakage w ith a blow er door. Below a few are discussed, but f irst w e w ill reviewterminology. The simplest blow er door test on a single family home measures only the leakage of the exterior envelope, w hich can be referred to as"exterior leakage." In multifamily buildings, there are lots of other air leakage pathw ays besides from the exterior, and a blow er door test on a single unitw ill measure some leakage from outside and some "inter-unit" leakage from other spaces. Multifamily buildings typically have lots of inter-unit leakage,but it's exterior leakage from the outside that relates most directly to energy consumption.

Similar to a single-family home test, whole-building leakage testing uses one or more blow er door systems to pressurize or depressurize the entirebuilding at once, measuring all the exterior air leakage in one shot. Because all spaces in the building are under the same pressure, inter-unit leakage isnegated. An excellent description of the process w as given by Don Hynek in Home Energy Magazine in September 2011. For a larger building thismethod often requires multiple blow er doors and experienced technicians to conduct properly. Factors such as building height, design, stage ofconstruction, and especially w eather on the testing day can make a w hole-building test a challenge. Still, this test is quite popular, particularly in Europe.

Another method is guarded blow er door testing, w hich also requires multiple blow er doors and experienced technicians to perform. It also aims tomeasure exterior envelope leakage by manipulating inter-building pressures w ith multiple fans. Figure 1 illustrates this technique in more detail. It's called


http://www.dos.ny.gov/DCEA/pdf/2015EnergyCodeSupplementdraft20151106.pdf.

guarded testing because it uses secondary "guard" blow er doors placed around the target unit. These are maintained at the same test pressure as thetarget unit, w hich neutralizes any inter-unit leakage. The result is that only exterior leakage is recorded from the target unit. By moving the doors arounda building like a tic-tac-toe board, the exterior leakage of all the spaces can be isolated and recorded. The time-consuming process requiresexperienced operators, a good plan, and several blow er doors even for a small multifamily building. This method is often used for research, but it is alsoa practical w ay to test some tow nhouse building configurations.

By comparison, single-unit or compartmentalization testing (the terms are used interchangeably here) is simpler than other methods. A singletechnician w ith a single blow er door moves around the building and tests each unit individually. Because no steps are taken to nullify leakage from otherapartments as in w hole-building or guarded testing, this test quantif ies leakage from the exterior w alls as w ell as the interior demising w alls, f loors, andceilings of a unit. Experienced technicians w ill tell you that it is common for this inter-unit leakage to rival or even exceed that of the exterior leakage.Because exterior leakage is really w hat matters for energy use, this test is not very useful for energy cost calculations.

Which test is best?

Each test has its merits, but w hen industry professionals including Steven Winter Associates (SWA) w ere asked to help guide New York State's codescouncil on testing language in the building code, they specif ically recommended single-unit tests. In their opinion, guarded blow er door testing is mostuseful as a research tool, and w hole-building testing can be too complicated and expensive to require on a state level. But if single-unit test results arenot useful for calculating energy savings, w hy use them for an energy-focused building code? The reasons are both practical and forw ard-thinking.

Above all, for a code provision to be beneficial, it needs to be enforceable. More than the other methods, single-unit testing is easiest to introduce on astatew ide basis. It requires less training, experience, and equipment than w hole-building tests. Many of our nation's netw ork of HERS raters and BPIprofessionals are all already qualif ied for it. As described below , the additional cost to builders in many cases w ill be less for single-unit tests than forother methods w hen sampling protocols are used.

There are several complications w ith conducting w hole-building tests on a w ide scale that make it more troublesome to require by code. First, theselarge tests have high mobilization costs, and there are few er companies that ow n either high-pow ered fans or multiple blow er doors for biggerbuildings. Second, the entire building has to be prepared (central exhaust registers taped, w indow s locked, central fans sw itched off, etc.) before thetest can be conducted – for a large building this can take several hours. Workers also cannot enter or leave the building during the test; it must be"locked dow n." For this reason it is virtually impossible to do a big blow er door test early in construction because w ork on the building cannot stop.Punch list time is ideal because few er w orkers are present, but f ixing big problems at that stage is much more expensive.

A single-unit test can be more useful to builders – it can be used to check progress and identify problems very early in construction w hen they arecheaper to f ix. A tester can leap-frog and w ork around other trades in the building, reducing the disruption to regular w orkflow . If a unit passes theblow er door test early on, the job is done; if not, f ixes can be applied and a retest can be done in minutes. The possibility of demonstrating complianceearly is very attractive because it reduces uncertainty and potential cost at the end of the project. In fact, a higher-volume builder may decide topurchase a blow er door kit and self-check periodically. Wouldn't it be a very positive side-effect if the blow er door became a common tool of thebuilders of tomorrow ?

One might argue that a compartmentalization test yields a number that is essentially useless for energy models because it measures mostly interiorleakage. That is largely true. But the goal of an energy code requirement is to save energy, and requiring and testing compartmentalization w ill do that.By paying attention to leaks of all types – interior and exterior – the goals of energy conservation w ill be met.

As for utility incentive programs that rew ard tight building exteriors, the builder may have to do a w hole-building test at the end, but this is a much lessw orrisome prospect if many smaller tests have been done all along. Alternatively, some attempts have been made to f ind links betw een single-unit,guarded, and w hole-building blow er door test data, and to arrive at "factors" for converting results from single-unit tests to exterior leakage f igures thatare more useful to energy models. This is as complicated as it sounds, and the best summary of that research is that more research is needed (Faakye,


Arena, and Grif f iths 2013). One might argue for an alternative compliance option in the code that allow s w hole-building testing. But compartmentalizationis a valuable goal in itself, and w hole-building and guarded blow er door tests do not take it into account.

Voluminous research indicates the benefits of more airtight apartments. Compartmentalized units are safer in a f ire because they reduce transfer ofsmoke and hot gasses betw een units. They are healthier because they reduce the transfer of second-hand smoke, odors, and other pollutantsbetw een neighbors and attached garages. They are more comfortable because they help to reduce drafts and cold complaints, and reduce soundtransfer betw een units. They offer better control of heating, cooling, and ventilation because uncontrolled air movement is minimized. They also reducepathw ays for bugs and vermin to travel betw een units. Guarded blow er door testing and w hole-building leakage testing, w hile they are better atquantifying energy benefits of a tight exterior, turn a blind eye to these benefits.

Part of the impetus for moving in this direction w as years of research into ventilation, airf low s, and compartmentalization. Because multifamily buildingshave complex netw orks of inter-space airf low , controlling the many pathw ays becomes very important to ensuring that the air that enters a unit is froma clean, healthy source. It turns out to be extremely hard to get fresh air into apartments w hen and w here you w ant it if you don't have substantiallyairtight apartments. According to research from SWA and others, exhaust-only ventilation, the most common design in multifamily buildings, often draw smore air from other apartments than it does from fresh sources such as vents in the w indow or HVAC.

Compartmentalization testing leads the building industry in the right direction. It fosters a natural alliance betw een f ire safety, health, and energyconservation professionals that other test methods may not. It is easy to explain and understand even for someone w ho has never seen a blow er door,and the immediate benefits are apparent to builders, residents, and landlords alike. It also takes the building industry as a w hole in a progressivedirection by actually quantifying compliance w ith requirements for unit separation. Currently, enforcement of unit f ire-stopping requirements currentlyrelies on visual inspections by code off icials, so compliance is in practice somew hat subjective. Testing w ith a blow er door backs that assessment upw ith a real number that is easy to verify w ith another test.

It is easy to imagine next steps from here. One obvious step is to require blow er door testing of apartments in larger residentially-classif ied commercialbuildings. It is also possible to look forw ard a decade to w hen compartmentalization of other major spaces – boiler rooms, trash rooms, and evenseparate leases in commercial buildings – is verif ied w ith a blow er door. Who w ould not like to verify that a boiler room is isolated from the rest of alarge building? A quick test w ith a blow er door w ill do that. This is the direction the industry should go.

Defining an appropriate building code requirement for compartmentalization testing

After review ing the advantages of compartmentalization testing over other methods, let us review some reasonable language to be considered bycodes councils considering its adoption. The language that SWA recommended to the NY Codes Council is largely aligned w ith language from ASHRAE62.2-2013, LEED BD+C: Multifamily Midrise, and the EPA's ENERGY STAR® Multifamily High Rise program, w hich call for a maximum leakage rate of 0.30cubic feet of leakage per minute at 50 Pascals per square foot of apartment envelope area (0.3 CFM50/SF), w hich includes the f loors, ceilings, andinterior and exterior w alls of an apartment.

How appropriate is this threshold? Steven Winter Associates maintains a database of multifamily blow er door tests that it has conducted over the pastf ive years in the course of certifying thousands of units of green and high-performance housing in New York State, and it show s that this threshold isgenerally achievable. Figure 3 show s graphically the results of over 600 of these tests. In the database, 88% of units tested in the SWA portfolio meet0.30 CFM50/SF. While most of the projects participated in some sort of utility program that required compartmentalization, it clearly show s that thethreshold is w ithin reach for builders that make an effort.


The changes to the 2015 IECC for New York State's Energy Code w ere conceived by Steven Winter Associates, Inc., a consulting and researchcompany w ith off ices in New York, Connecticut, and Washington, D.C. The proposal gained the support of many in the building science industry,including the follow ing w ho signed a letter of support:

James P. Stahl Jr., Specified Technologies Inc. – f ire protection expert

Armin Rudd, Principal, ABT Systems LLC – recognized expert in multifamily housing research, member of ASHRAE 62.2 Envelopes Subcommittee,expert in code issues surrounding f ire-stopping

Paul W. Francisco, Director, Univ. Illinois Weatherization Training Center – expert in indoor air quality research and a member of ASHRAE 62.2Envelopes Subcommittee

Terry Brennan, Camroden Associates – expert in building testing and indoor environmental quality; member of ASHRAE 62.2 committee

Richard Leigh, Director of Research, Urban Green Council – leader in green building industry research in New York State for U.S. Green BuildingCouncil's New York Chapter

Asa Foss, Director Residential Technical Solutions, U.S. Green Building Council – expert in technical issues for U.S. Green Building Council'sLeadership in Energy and Environmental Design

Ellen Tohn, Principal and Founder, Tohn Environmental Strategies – recognized expert in indoor environmental quality research.

Gary Nelson, The Energy Conservatory – inventor of the Minneapolis Blow er Door, the w idest-selling blow er door kit in the United States and arecognized expert in inf iltration testing.

Sean Maxwell, Senior Energy Consultant, Steven Winter Associates – lead researcher on several studies of building compartmentalization andventilation performance for DOE Building America

Bibliography: ASHRAE (2013). ANSI/ASHRAE Standard 62.2-2013 addendum e: Ventilation for Acceptable Indoor Air Quality in Low -Rise Residential Buildings.Atlanta, GA: ASHRAE. 8.4.1.1 Compliance. Page 5.

https://w w w .ashrae.org/File%20Library/docLib/StdsAddenda/62_2_2013_2015Supplement_20150226.pdf

ENERGY STAR MFHR Testing and Verif ication Protocols Version 1.0. Page 75.

http://w w w .energystar.gov/ia/partners/bldrs_lenders_raters/dow nloads/mfhr/ENERGY%20STAR%20MFHR%20TV%20Protocols_Version_1_Rev03.pdf?0544-2a1e

Hynek, Don (2011). Blow er Door Testing in Multifamily Buildings. Home Energy Magazine. September 2011.

http://w w w .homeenergy.org/show /article/nav/blow erdoor/id/1711/page/2.


https://www.ashrae.org/File Library/docLib/StdsAddenda/62_2_2013_2015Supplement_20150226.pdf

http://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloads/mfhr/ENERGY STAR MFHR TV Protocols_Version_1_Rev03.pdf?0544-2a1e

http://www.homeenergy.org/show/article/nav/blowerdoor/id/1711/page/2.

RE56-16 : R402.4 (NEW)-MAXWELL9968

LEED: Homes Design and Construction. Version 4. Prerequisite 7. Compartmentalization.

Faakye, L. Arena, D. Grif f iths (2013). "Predicting Envelope Leakage in Attached Dw ellings." July 2013. Washington, DC; Building America BuildingTechnologies Program, Off ice of Energy Eff iciency and Renew able Energy, U.S. Department of Energy. http://w w w .nrel.gov/docs/fy13osti/58669.pdf

RESNET Sampling Standard.

http://w w w .resnet.us/rater/Sampling_Standard.pdf

Cost Impact: Will not increase the cost of constructionCost ComparisonThe proposed changes w ould result in a net cost savings to the construction industry. The reason is that the test methods are simpler, faster, and canbe done by a much w ider segment of the industry. In many cases, single-unit tests are less expensive than w hole-building tests because they requiresignif icantly less equipment and few er personnel. The above mentioned September 2011 article in Home Energy by Don Hynek, a very experiencedmultifamily professional, gives an example of a w hole-building test of a 50-unit building that used f ive blow er doors and six technicians at a cost ofabout $6,000, or $120 per apartment. Single-unit testing may only cost less than w hole-building testing if sampling protocols are used. Defined andcarried out correctly, these can be effective and cost-saving. Based on concepts from RESNET's Sampling Standard, SWA recommended a minimumsampling rate of one in seven units after an initial round of successful tests.

Figure 2 below illustrate cost estimates for testing buildings in a mature market w ith experienced technicians. A cost comparison betw een w hole-building testing and single-unit testing is made, for multifamily buildings w ith interior-entry (shared hallw ay) layout and for tow nhome configuration. Thenumber of man-hours is estimated for a range of building sizes, and a typical cost for a blow er door technician of $90 per hour is assumed. Amobilization cost of $200 per blow er door per day to account for transportation and setup of equipment is included as w ell. By these estimates, the costfor testing is low er w hen using single-unit tests, possibly less than half the cost of w hole-building tests for buildings of equivalent size. Of coursethese are only theoretical f igures and vary greatly from project to project, and you are encouraged to make your ow n estimates.


http://www.nrel.gov/docs/fy13osti/58669.pdf

http://www.resnet.us/rater/Sampling_Standard.pdf

RE57-16 : R402.4-CONNER12732

RE57-16R402.4 (IRC N1102.4), R402.4.1 (IRC N1102.4.1), R402.4.1.1 (IRC N1102.4.1.1), R402.4.1.2 (IRCN1102.4.1.2), R402.4.1.3 (New) [IRC N1102.4.1.3 (New)]Proponent : Craig Conner ([email protected])


R402.4 (N1102.4) Air leakage (Mandatory). The building thermal envelope shall be constructed to limit air leakage inaccordance with the requirements of Sections R402.4.1 through R402.4.5 R402.4.4.

R402.4.1 (N1102.4.1) Building thermal envelope. The components of the building thermal envelopeas indicated in TableR402.4.1.1 shall comply be installed in accordance with Sections R402.4.1.1 the manufacturer's instructions and R402.4.1.2 the criteria indicated in Table R402.4.1.1, as applicable to the method of construction. The sealing methods between dissimilarmaterials Where required by the code official, an approved third party shall allow for differential expansion inspect allcomponents and contraction verify compliance with this section.

R402.4.1.1 (N1102.4.1.1) Installation. (Mandatory) The components of the building thermal envelopeas listed indicated inTable R402.4.1.1 shall be installed in accordance with the manufacturer's manufacturer's instructions and the criteria listed indicated in Table R402.4.1.1, as applicable to the method of construction. Where required by the code official, anapprovedthird party shall inspect all components and verify compliance with the manufacturer's instructions and the criteria ofTable R402.4.1.1.

R402.4.1.2 (N1102.4.1.2) Testing. (Mandatory) The building or dwelling unit shall be tested and verified as having an for airleakage rate not exceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones3 through 8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported using a blower dooroperating at a pressure of 0.2 inch w.g. (50 Pascals). Where required by the code official, testing shall be conducted by anapprovedthird party. A written report of the results of the test shall be signed by the party conducting the test and provided tothe code official. Testing shall be performed at any time after creation of all penetrations of the building thermal envelope and .

During testing, all of the following conditions shall be met:


2. Dampers including exhaust, intake, makeup air, backdraft and flue dampers shall be , closed, but not sealedbeyond intended infiltration control measures.

3. Interior doors, if Where installed at the time of the test testing, shall be open interior doors opened.4. Exterior doors for continuous ventilation systems and heat recovery ventilators shall be , closed and sealed.5. Heating and cooling systems, if Where installed at the time of the test testing, shall be heating and

cooling systems turned off.6. Supply and return registers, if Where installed at the time of the test testing, shall be supply and return

registers fully open.


R402.4.1.3 (N1104.1.3) Leakage limit (Prescriptive). The air leakage rate of a building or dwelling unit in Climate Zone 1 or 2shall not exceed 3 ACH. The air leakage rate of a building or dwelling unit in Climate Zone 3, 4, 5, 6, 7 or 8 shall not exceed 5ACH.

Reason: This is similar to the online draft DOE posted in the last code cycle, w ith revisions to make the code clearer.

Theis proposal makes the duct tightness tradable. DOE's posted reason statement said it w ell:

"Changing the envelope air leakage rate from mandatory to prescriptive will allow builders the option of trading improvements in other buildingcomponents for less stringent pressure test results. This provides flexibility in meeting the requirements and options for recovering from anunexpected test failure. The proposed change retains a mandatory pressure test and leaves all other aspects of envelope sealing mandatory".These modif ications remove the mandatory maximum air tightness requirement and provide designers and builders the f lexibility to trade-off buildingtightness w ith other performance path measures w hen using the performance path. Currently the building tightness requirement is mandatory and the 3and 5 ACH tightness levels even under ideal circumstances, are very dif f icult to achieve. This w ill provide energy neutral trade-offs for expensive andsometimes unattainable requirements w ith other building improvements. This proposal does not change the stringency of the code it only increases theflexibility.

Cost Impact: Will not increase the cost of constructionTradeoff options tend to decrease the overall cost of construction.


RE58-16R402.4 (IRC N1102.4), R402.4.1.1 (IRC N1102.4.1.1), R402.4.1.2 (IRC N1102.4.1.2), R402.4.1.3 (New)[IRC N1102.4.1.3 (New)], R402.4.1.4 (New) [IRC N1102.4.1.4 (New)]Proponent : Donald Surrena ([email protected])


R402.4 (N1102.4) Air leakage (Mandatory). No change to text.

R402.4.1.1 (N1102.4.1.1) Installation (Mandatory). No change to text.

R402.4.1.2 (N1102.4.1.2) Testing (Mandatory). The building or dwelling unit shall be tested and verified as having an for airleakage rate not exceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones3 through 8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2inch w.g. (50 Pascals). Where required by the code official, testing shall be conducted by an approved third party. A writtenreport of the results of the test shall be signed by the party conducting the test and provided to the code official. Testing shallbe performed at any time after creation of all penetrations of the building thermal envelope.

During testing:





R402.4.1.3 (N1102.4.1.3) Maximum Air Leakage Rate (Mandatory) The maximum Air Leakage permitted using thePerformance Alternative from Section R405 shall be 6 ACH in Climate Zones 1 and 2, and 5 ACH in Climate Zones 3 through 8when tested in accordance with Section R402.4.1.2.

R402.4.1.4 (N1102.4.1.4) Leakage Rate (Prescriptive) The building or dwelling unit shall have an air leakage rate notexceeding 5 air changes per hour in Climate Zones 1 and 2, and 3 air changes per hour in Climate Zones 3 through 8, whentested in accordance with Section R402.4.1.2.

Reason: These modif ications remove the mandatory maximum air-tightness requirement and provide designers and builders the f lexibility to trade offbuilding tightness w ith other performance path measures w hile also providing a limit to that f lexibility. Currently the building tightness requirement ismandatory and the 3 and 5 ACH tightness levels, even under ideal circumstances, are very dif f icult to achieve. This w ill provide energy neutraltradeoffs for expensive and sometimes unattainable requirements w ith other building improvements. This proposal does not change the stringency oreff iciency of the code; it only increases the f lexibility.DOE has verif ied that achieving 3 ACH50 is problematic, even in Maryland w ho has had a 3 ACH requirement for over 3 years (see chart below ).


Cost Impact: Will not increase the cost of construction


RE58-16 : R402.4-SURRENA12449

This performance option provides f lexibility in meeting the air tightness requirements and w ould allow less expensive alternatives for recovering from anunexpected air tightness test failure.


RE59-16 : R402.4-SURRENA12466

RE59-16R402.4 (IRC N1102.4)Proponent : Donald Surrena ([email protected])


R402.4 (N1102.4) Air leakage (Mandatory). The building thermal envelope shall be constructed to limit air leakage inaccordance with the requirements of Sections R402.4.1 through R402.4.5. Alternatively, dwelling units in Group R-2occupancies and dwelling units in buildings having two or more attached single family dwellings shall comply with IECCSection C402.5.

Reason: Air tightness testing for single-family detached homes is very straightforward; however, it is much more difficult to accurately test attacheddwelling units, including multi-family buildings. Currently the IECC treats low-rise multifamily buildings of three stories or less like single-familyhomes and multifamily buildings of four stories or more like commercial buildings. Regardless of height, all multifamily buildings have the same air-tightness testing complications, such as: Does the entire building need to be tested at one time? What about multifamily buildings with opencorridors? Does every dwelling need to be tested? Can the leakages be averaged between units? Is the leakage tested only to the "outside" or shouldit include leakage to adjacent units? By approving this change, low-rise multifamily buildings and attached single-family dwellings will avoid these complications, but still held to the samelevel of performance as high-rise (R-2) residential as well as all commercial buildings.

Cost Impact: Will not increase the cost of constructionThe code change proposal will not change the cost of construction. Code requirements are not proposed to be changed, rather clarified as to theintent of the current code.


RE60-16R402.4 , R402.4.1, R402.4.1.1, R402.4.1.2, R402.4.1.3 (New), R402.4.2, R402.4.3, R402.4.4, R402.4.5(IRC: N1102.4 ,N1102.4.1, N1102.4.1.1, N1102.4.1.2, N1102.4.1.3 (New), N1102.4.2, N1102.4.3,N1102.4.4, N1102.4.5)Proponent : Jeremiah Williams ([email protected])


R402.4 (N1102.4) Air leakage (Mandatory). No change to text.

R402.4.1 (N1102.4.1) Building thermal envelope. The building thermal envelopeshall comply with Sections R402.4.1.1,R402.4.1.2, and R402.4.1.2 R402.1.3. The sealing methods between dissimilar materials shall allow for differential expansionand contraction.

R402.4.1.1 (N1102.4.1.1) Installation (Mandatory). No change to text.

R402.4.1.2 (N1102.4.1.2) Testing (Mandatory). The building or dwelling unit shall be tested and verified as having an todetermine envelope air leakage rate not exceeding five air changes per hour in Climate Zones 1 and 2, and three air changesper hour in Climate Zones 3 through 8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 andreported at a pressure of 0.2 inch w.g. (50 Pascals). Where required by the code official, testing shall be conducted by anapproved third party. A written report of the results of the test shall be signed by the party conducting the test and provided tothe code official. Testing shall be performed at any time after creation of all penetrations of the building thermal envelope.

During testing:





R402.4.1.3 (N1102.4.1.3) Envelope air leakage (Prescriptive) Envelope air leakage, when tested in accordance withSection R402.4.1.2, shall not exceed 5.0 air changes per hour in Climate Zones 1 and 2, and 3.0 air changes per hour inClimate Zones 3 through 8.

Revise as follows:

R402.4.2 (N1102.4.2) Fireplaces (Mandatory). No change to text.

R402.4.3 (N1102.4.3) Fenestration air leakage (Mandatory). Windows, skylights and sliding glass doors shall have an airinfiltration rate of no more than 0.3 cfm per square foot (1.5 L/s/m2), and swinging doors no more than 0.5 cfm per square foot(2.6 L/s/m2), when tested according to NFRC 400 or AAMA/WDMA/CSA 101/I.S.2/A440 by an accredited, independentlaboratory and listedand labeledby the manufacturer.

Exception:Site-built windows, skylights and doors.

R402.4.4 (N1102.4.4) Rooms containing fuel-burning appliances (Mandatory). In Climate Zones 3 through 8, where opencombustion air ducts provide combustion air to open combustion fuel burning appliances, the appliances and combustion airopening shall be located outside the building thermal envelope or enclosed in a room, isolated from inside the thermal envelope.Such rooms shall be sealed and insulated in accordance with the envelope requirements of Table R402.1.2, where the walls,floors and ceilings shall meet not less than the basement wall R-value requirement. The door into the room shall be fullygasketed and any water lines and ducts in the room insulated in accordance with Section R403. The combustion air duct shallbe insulated where it passes through conditioned space to a minimum of R-8.

Exceptions:1. Direct vent appliances with both intake and exhaust pipes installed continuous to the outside.2. Fireplaces and stoves complying with Section R402.4.2 and Section R1006 of the International Residential

Code.

R402.4.5 (N1102.4.5) Recessed lighting (Mandatory). Recessed luminaires installed in the building thermal envelopeenvelope shall be sealed to limit air leakage between conditioned and unconditioned spaces. All recessed luminaires shall beIC-rated and labeled as having an air leakage rate not more than 2.0 cfm (0.944 L/s) when tested in accordance with ASTM E283 at a 1.57 psf (75 Pa) pressure differential. All recessed luminaires shall be sealed with a gasket or caulk between thehousing and the interior wall or ceiling covering.

Reason: This proposal increases f lexibility by giving builders compliance options for homes w ith higher envelope air leakage. Because the existing airleakage requirements are mandatory, builders have limited recourse if a f inished home fails to meet the required leakage level. By allow ing air leakage tobe traded off through the performance path, builders have the option of improving other envelope elements to offset higher air leakage, or simplyhedging against failed leakage tests by implementing modest improvements elsew here in the home.


RE60-16 : R402.4-WILLIAMS12243

Energy Savings: The proposal is designed to be energy neutral.

The U.S. Department of Energy (DOE) develops its proposals through a public process to ensure transparency, objectivity and consistency in DOE-proposed code changes. Energy savings and cost impacts are assessed based on established methods and reported for each proposal, as applicable.More information on the process utilized to develop the DOE proposals for the 2018 IECC can be found at: https://w w w .energycodes.gov/development/2018IECC.

Cost Impact: Will not increase the cost of construction Because tradeoffs w ith air leakage are optional, there is no direct cost impact. Cost-effectiveness: This change is cost-effective in that it is expected to provide neutral energy impact, and is optional.



RE61-16Table R402.1.1 (IRC Table N1102.1.1)Proponent : Thomas Bren, representing Thomas Bren Homes, Inc.









material.

Ceiling/attic







Walls



be sealed.










Sealing methods and materials shall be applied in a manner

that does not restrict drainage of incidental moisture f rom

around window assemblies.





insulation.














Narrow cav ities





conditioned spaces.






RE61-16 : R402.4.1.1-BREN12826

Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Add new language to clarify the intent, and enhance the effectiveness, of proper w indow installation requirements. Moisture is the mostsignif icant factor in the deterioration of buildings, and w indow assembles are the most vulnerable to moisture inf iltration. The existing code languagedoes not have specif ic, enforceable code language to require maintaining an effective drainage plane around w indow assemblies. For all points ofmoisture intrusion to be eliminate, the w orkmanship must be perfect. How ever, even a perfectly f lashed and caulked w indow w ill suffer degradationover time due to environmental conditions. For this reason, it is necessary to incorporate some redundancy in the process. It is inevitable that somemoisture w ill enter the w indow frame opening. This moisture must be allow ed to escape from the assembly to avoid structural damage and moldgrow th. When the area behind the nailing f lange is obstructed, the blockage itself or capillarity w ill restrict drainage. An air space or free drainingmaterial in a w indow assembly, behind the w ater shedding surface, is an excellent w ay to prevent insulation or other materials from reaching theinterior side of the nailing f lange or installing a material that allow s free draining and air movement. This air space or free draining material w ill be lessexposed to the elements and linear expansion, allow ing it to last longer than exterior caulking, etc.

Bibliography: Research Highlights, Technical Series 03-124, CMHCKeeping Walls Dry - Parts 1 & 2, CMHC, Dale Kerr - P. Eng.

Cost Impact: Will increase the cost of constructionDepending upon the methods used, there may be a slight increase in the cost of compliance due to labor and a small amount of materials. How ever, thebenefits of ensuring moisture drainage and reducing the potential for structural damage and mold grow th far outw eigh the minor costs that may beinvolved.The cost impact of this additional step to install a method to stop insulation or other material from reaching the interior side of the nailing f lange, includingmaterial and labor, can be expected to add betw een $10 - $20 per w indow opening. This is contingent upon the size of the opening, but in most casesw ill fall into this range. This cost is a fraction of that applied to the remediation required for a system w hich fails.

The follow ing are examples of remediation costs that w ould be avoided based on feedback from builders, remodelers, and construction experience:

Initial site visit: $200 -$500

R&R of single unit: $1,500 - $5,000

R&R of multiple units w ith extensive damage has ranged from thousands of dollars to exceeding the value of the structure.


RE63-16Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Howard Ahern, representing self ([email protected])









material.

Ceiling/attic







Walls



be sealed.














insulation.














Expanding f oam shall not be used to seal penetrations of

the air barrier by ref rigerant piping

Narrow cav ities





conditioned spaces.


RE63-16 : TABLE R402.4.1.1-AHERN11653





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Vibration problems of refrigerant piping is w ell know n and is addressed in the International Mechanical Code but not for sealing of thesepenetrations .The Department of Energy recommends using only in non -friction areas, as material can become dry and pow dery over time. Constantfriction from vibration of the refrigerant piping w ill degrade and destroy the foam producing leakage and for this application it should not be used for asustainable sealing method for this type of penetration. There are plenty of other materials and methods already being used for this application such asa variety of caulking, sealing, and gaskets materials. Polyurethane, expandable spray foam is a great product for sealing other pipe penetrations that donot vibrate or have vibration problems and this change applies only to the sealing of the refrigerant pipe penetrations.

Bibliography: Department of Energyenergy.gov

Caulking

http://w w w .energy.gov/energysaver/caulking

Cost Impact: Will not increase the cost of constructionWill not increase cost . There are plenty of other materials and methods already being used such as a variety of caulking, sealing, and gasketsmaterials. Will save cost associated w ith air leakage of refrigerant piping penetrations.


RE64-16Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Michael Gieszler, representing Oregon Building Officials Association ([email protected])

2015 International Energy Conservation Code








material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







RE64-16 : TABLE R402.4.1.1-GIESZLER10923

Plumbing and wiring plumbing in exterior walls, or insulation that on installation


piping and wiring.




insulated.



HVAC register boots

HVAC register boots that penetrate the building thermal

env elope shall be sealed to the subf loor, wall cov ering or

dry wallceiling.






walls or ceilings.


Reason: HVAC register boots are installed in ceilings as w ell as w alls and f loors and should be sealed regardless of w hich part of the thermalenvelope they pass through.

Cost Impact: Will not increase the cost of constructionThis proposal only clarif ies the intent of the code. There is no additional materials or labor costs associated as this w ork is w hat the current codeintends.











material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.


env elope shall be sealed to the dry wall f inished surf ace.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: The intent of the code is that w hatever the f inish surface, penetrations must be sealed to it.

Cost Impact: Will not increase the cost of constructionThis proposal only clarif ies the code provision for sealing. As this is only a clarif ication, there is no additional cost associated w ith this proposedchange.


RE66-16Table R402.4.1.1 (IRC TABLE N1102.4.1.1)Proponent : Michael Gieszler, representing Oregon Building Officials Association ([email protected])









material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.

Shower/tub on exterior wall

TheAn air barrier shall be installed at on the interior of exterior

wallsassemblies adjacent to showers and tubs shall separate

them f rom the showers and tubs. where porous insulation is

installed.


insulated.










walls or ceilings.


Reason: An air barrier is necessary behind a tub/show er unit to prevent convection and moisture intusion into porous insulation. The present w ordingdoes not require an air barrier betw een the w all and the insulation. It is important to aff irmatively state that an air barrier shall be located on the interiorof the w all assembly at this location.

Cost Impact: Will not increase the cost of constructionThe proposal is a clarif ication of the intent of the code and does not require any more material or labor for the construction of the building.











material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.

Factory -built f ireplaces

An air barrier shall be installed on the interior of thermal

env elope assemblies adjacent to a f actory built f ireplace

where porous insulation is installed.

Exterior walls adjacent to f actory built f ireplaces shall be

insulated.


Reason: An air barrier is necessary in w alls behind factory built f ireplaces to prevent convention and moisture intursion in porous insulation.

Cost Impact: Will not increase the cost of constructionThis clarif ies code intent. No additional cost associated w ith this proposal.


RE68-16Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Shaunna Mozingo, representing Colorado Chapter of ICC Energy Code Development Committee([email protected])









material.

Air-permeable insulation is inside of an air barrierb

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.

Recessed lightingRecessed light f ixtures installed in the building thermal Recessed light f ixtures installed in the building thermal


RE68-16 : TABLE R402.4.1.1-MOZINGO12890

env elope shall be sealed to the dry wall. env elope shall be air tight and IC rated.

Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.

a. In addition, inspection of log walls shall be in accordance with the prov isions of ICC-400.b. Insulation encapsulation not required in unconditioned attic space or where utilizing the exception f or f loors.

Reason: In the 2009 IECC w e had this w ording that the air permeable insulation had to be inside of an air barrier. You have to encapsulate theinsulation in order for it to w ork. In the 2012 it w as taken out because it didn't need to be inside of an air barrier in the attic so it w as discussed justplacing the requirement in the w all portion of the table and not in the general section. The f loor section already said that the insulation had to be inpermanent contact w ith the sub-f loor and have an air barrier so no need for it there is w hat w e w ere told.Well w hat w e are f inding in the f ield does not line up w ith this reasoning. The people that knew it w as there in 2009, see that it is gone in the 12 and 15and therefore think that it doesn't have to happen anymore. You have to go through manufacturer's install instructions and all of the other w ording ofthe code to show them that they still need it in f loors and w alls. It w ould be much easier if w e just put it back and made the exception for the ceilingsand also for the new exception that w ent in by Joe Lstiburek for the f loors.

Air permeable insulation does need to be inside of an air barrier. Why can't w e just say that again? If it's implied, then let's just actually say it.

Cost Impact: Will not increase the cost of constructionThe requirement hasn't changed, w e have just added it to general instead of only be located in the f loor and w all section that already exists.


RE69-16 : TABLE R402.4.1.1-SCHWARZ13046

RE69-16R202 (IRC N1101.6), Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R202 (N1101.6) GENERAL DEFINITIONS

ADIABATIC.A condition where there is assumed to be no gain or loss of energy across a building assembly.

Revise as follows:



Common adiabatic walls, f loors and ceilings An air barrier shall be installed at the perimeter

connections of these walls, f loors and ceilings to the

exterior or unconditioned space.

Air barrier details described in Table R402.4.1.1 that

are adjacent to these walls, f loors and ceilings shall

be installed and sealed.

The installation of any cav ity insulation in these walls,

f loors and ceilings, f or any purpose including that

required f or the f ire resistance rating of the

assembly , shall be to a grade 1 installation quality

lev el.


Reason: The primary reason attached housing is f inding it dif f icult to achieve the air leakage requirements of the IECC is due to leakage associated w ithcommon adiabatic w alls, f loors, ceilings. These assemblies w ere removed from this table but they need attention. Research performed by IBACOSthrough the Building America Program has indicated that UL already allow s solid air barrier material to be placed in the gap created in shaft w allassemblies. UL has indicated that air sealing is allow ed as w ell. Treating common adiabatic w alls, f loors, ceilings just like any other assembly that islocated to the exterior or to an unconditioned space ensures that air sealing and air barriers are installed w hen tubs, f ireplaces, drop ceilings and otherdetails are built adjacent to them.The same principals of insulation installation are required w hen insulating common adiabatic w alls, f loors, ceilings. The insulation needs to fully f ill theframed cavity and be split around any obstruction in the cavity. As there is a signif icant amount of exterior air f low ing through these assemblies properinsulation techniques is needed from an eff iciency perspective. In addition, sound f low s and is retarded by the same air pockets that retard the f low ofenergy. Therefore the SDC rating of the assembly also requires proper installation of insulation.

Lastly, there continues to be a signif icant disconnect betw een f ire code and energy code. Re-introducing this section to the code w ill continue to pushthe tw o groups tow ard a dialog and or Building America and other research organizations to f igure out solutions to the issues these assemblies create.

Cost Impact: Will increase the cost of constructionProperly addressing common adiabatic assemblies w ill add to the cost of construction but w ill allow builders to successfully meet the air leakagerequirements of the IECC. Currently air barrier and air sealing details are not being uniformly applied to common adiabatic assemblies. This proposalw ould require that be done so the cost associated w ith this w ould be for air barrier materials and labor. It is estimated that the cost w ould be in the$100-$500 range per unit.


RE70-16Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])









material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.

Where required to install f ire sprinkler sy stems outside the

building thermal env elope, the insulation tenting shall be

installed so as to limit the disruption to the integrity and

continuity of the buildings thermal env elope.

Where possible, the f ire sprinkler sy stems shall be

installed inside the building thermal env elope to ensure that

the integrity and continuity of the building's thermal

env elope is maintained.


Reason: There continues to be a signif icant disconnect betw een f ire code and energy code. The current air barrier criterion for sprinkler installation ismore of a recommendation than a fast requirement. Its goal is to promote a tighter building envelop w hile not superseding the f ire code. In the same w aythe insulation criteria is designed to ensure that designers think more about the place of the f ire suppression system and the possible alternativesystems that are available. In addition, the proposal begins to allow some level of inspection of the quality of the installation of the insulation that is beinginstalled around the sprinkler system. Currently, our experience is that the tenting installation is horrendous and there is little or nothing that can be doneto address the situation. If nothing else this proposal w ill begin a dialogue that can continue for a three year cycle w hen maybe more impactful can beproposed.

Cost Impact: Will increase the cost of constructionThere may be minimal cost implications associated w ith this proposal as some inspectors should be requiring re-installation of the tenting insulationbased off of this language. Re-installation fees may be charged and re-inspections fees may occur.











material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.



HVAC register boots

HVAC supply and return register boots that penetrate building

thermal env elope shall be sealed to the subf loor or

dry wall penetrated by the boot.






walls or ceilings.


Reason: For minimal additional effort, this proposal ensures that the durability, comfort, health safety, and eff iciency intent of the code is carried out.When forced air passes through a supply boot a portion of that air is directed into building cavities the boot penetrates. In the same fashion a portion ofthe air that is returned to the HVAC system is pulled from the cavity rather than from the room w hen the boot is not sealed to the surface they penetratethrough. Air transports moisture, energy, and pollutants. Gaining greater control of the air that is moving through and around the building ensures bettereff iciency and compliance w ith the intent of the code.

Cost Impact: Will increase the cost of constructionThere is a minimal cost impact associated w ith this proposal. The duct system is already being sealed w ith mastic to meet the duct leakagerequirements of the code and the additional mastic installation needed to seal a supply boot to the subfloor is small.


RE72-16Table R402.4.1.1 (IRC N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])









material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.

Electrical/phone boxes on exterior wallsThe An air barrier shall be installed behind electrical or


Spaces behind electrical/phone boxes on exterior walls

shall be insulated or f illed by insulation that on installation









walls or ceilings.


Reason: This proposal is made for clarif ication and to ensure a common understanding of the requirment to properly insulate behind electrical boxes.

Cost Impact: Will not increase the cost of constructionThere is no cost implication associated w ith this proposal as the proposed language change clarif ies w hat already is required for insulation behindelectrical boxes. The space behind electrical boxes is the same as the insulation requirement in narrow cavities. These cavities are largely beinginsulated now this language adds additional clarity.




TABLE R402.4.1.1 AIR BARRIER AND INSULATION INSTALLATION







material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.

Shower/tub and f ireplaces on exterior

wall

The air barrier installed at exterior walls adjacent to showers

and tubs shall separate themexterior wall f rom the

showers,and tubs,and f ireplaces.

Tub and shower drain trap penetrations through the subf loor

shall be sealed.

Exterior walls adjacent to showers,and tubs, and f ireplaces

shall be insulated.










walls or ceilings.


Reason: During the last code cycle f ireplace cavities dropped off this air barrier and insulation table. This proposal adds the f ireplace back in andclarif ies that there must be separation betw een the exterior w all and the void cavities created by show er, tub, or f ireplaces. The proposal also adds adetail that w ill enhance house tightness and reduce condensation and moisture build up on the underside of the tubs and show er pans.

Cost Impact: Will increase the cost of constructionAir sealing and air barrier installation is already occurring in these locations. Small additional cost is expected if builders stopped installing air barriers inf ireplace cavities w hich in the Colorado market has not happened. In addition, some additional cost may occur in order to seal the drain trappenetration. How ever the benefit of this additional air sealing and it alignment w ith the intent of the code w ould outw eigh any additional cost.











material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities





conditioned spaces.







Plumbing,and wiring, and other

obstructions.Penetrations through the air barrier shall be sealed

Batt insulation shall be cut neatly to f it around wiring,and

plumbing, and other obstructions in exterior walls, f loors,

and ceilings. Alternativ ely ,whereor insulation that on

installation readily conf orms to av ailable space is used,

the insulation shall either extend behind, or shall

encapsulate piping, and wiring and any other obstructions

in insulated cav ities.




insulated.










walls or ceilings.


Reason: Plumbing, w iring, and other obstructions penetrate the buildings thermal envelope and w here that happens the penetration must be sealed.When these obstructions are w ithin an insulated cavity the insulation should fully encapsulate the obstruction as required by the insulation manufacture.This proposal ensures a clearer common understanding of how to successfully build w ith these conditions.

Cost Impact: Will not increase the cost of constructionThere is no cost implication associated w ith this proposal as it is primarily clarifying already codif ied requirements found elsew here in the code.











material.

Ceiling/attic







Walls



be sealed.














insulation.














Narrow cav ities Narrow cav ities that cannot be insulated shall be sealed.





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: There are many narrow cavities that cannot be insulated and there has been no direction in the code on how to deal w ith them until now .

Cost Impact: Will increase the cost of constructionThere is minimal cost implication associated w ith this proposal as w e are talking about adding expanding foam or caulk to some cavities that cannot beproperly insulated. It is estimated that the cost implications w ould be less than $50 per home, w hile the benefit derived from greater control andpredictability of the air f low , moisture f low , and thermal f low w ould be priceless. In addition, this language clarif ies w hat needs to happen w ith thesecavities that are too small for insulation.











material.

Ceiling/attic







Walls



be sealed.














insulation.












Shaf ts, penetrations

Duct shaf ts, utility penetrations, and f lue shaf ts opening, or

other similar penetrations to exterior or unconditioned space

shall be sealed.

Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: This proposal is made strictly for clarif ication and understanding for those practitioners or the code that utilize this table.

Cost Impact: Will not increase the cost of constructionThere is no cost implication associated w ith this proposal, as the requirements of the code are not proposed to change, rather the proposed languageclarif ies the intent of the current code.


RE77-16R402.2.11 (IRC N1102.2.11), Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R402.2.11 (N1102.2.11)Crawl space walls. As an alternative to insulating floors over crawl spaces, crawl space walls shall bepermitted to be insulated when the crawl space is not vented to the outside. Crawl space wall insulation shall be permanentlyfastened to the wall and extend downward from the floor to the finished grade level and then vertically and/or horizontally for atleast an additional 24 inches (610 mm). Exposed earth in unvented crawl space foundations shall be covered with a continuousClass I vapor retarder in accordance with the International Building Code or International Residential Code, as applicable. Alljoints of the vapor retarder shall overlap by 6 inches (153 mm) and be sealed or taped. The edges of the vapor retarder shallextend not less than 6 inches (153 mm) up the stem wall and shall be attached to the stem wall.

Revise as follows:








material.

Ceiling/attic







Walls



be sealed.














insulation.








Crawl space walls

Exposed earth in v ented or unv ented crawl spaces shall be

cov ered with a Class I v apor retarder in accordance with the

International BuildingCode or International Residential Code,

as applicable. with ov erlapping joints taped

Seams and edges of the v apor retarder shall ov erlap by 6

inches (153 mm) and shall be sealed. The edges of the v apor

retarder shall extend not less than 6 inches (153 mm) up the



As an alternativ e to insulating f loors ov er crawl

spaces where the crawl space is not v ented to the outside,

crawl space walls shall be insulated.

Crawl space wall insulation shall be permanently f astened

to the wall and extend f rom the crawl space f loor to the sill


RE77-16 : R402.2.11-SCHWARZ13027

stem wall of the f oundation and shall be sealed to the stem

wall, or other potential obstructions in the space.

plate attached to the top of the f oundation.



Narrow cav ities





conditioned spaces.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Delete Section R402.2.11 Craw l Space w alls as the prescriptive craw l space provisions of the IECC w ere essentially being reproduced in thismandatory table. The reality is that they should be mandatory for all pathw ays through the code to ensure that the intent of the code is maintained. Thisproposal puts the provisions in the correct place and clarif ies some areas that have been confusing to practitioners of the code for years. For example,in the past the code required that the craw l w all insulation extend dow nw ard from the f loor to the f inished grade level and then vertically and/orhorizontally for at least an additional 24 inches. I have never seen the insulation installed in this fashion and code off icials and builder alike neverunderstood if the f inished grade referred to the interior grade of the craw l space or the exterior f inished grade. This proposal clearly states how thew all insulation needs to be installed.

Cost Impact: Will increase the cost of constructionThere could be a small cost implication associated w ith this proposal. This proposal takes this prescriptive requirement and makes it mandatory w hichw ill have minimal to no cost implication as craw l spaces are being insulated now . This language clarif ies the current intent of the code and does notadd additional signif icant cost burdens. If there are any cost burdens it w ould be in the $100 range to do w hat they need to correctly.











material.

Ceiling/attic







Walls



be sealed.











Floors (including abov e garages, and

cantilev ered f loors, and v ented crawl

space f loors)

Floor sy stems shall hav e a continuously sealedThe air barrier

shall be installed at any exposed edge or perimeter f raming

membersof insulation.



decking so as to maintain insulations designed lof t or

readily f ill the av ailable cav ity space. or f loor f raming

cav ity insulation shall be permitted to be in contact with

the top side of sheathing,

or continuous insulation installed on the underside of f loor



Where any obstruction, such as a duct or pipe, is installed

in the f loor cav ity , f loor cav ity insulation shall be installed

in accordance with one of the f ollowing methods:

Method A:

The insulation shall be installed to be in permanent contact

with the underside of the subf loor decking. The insulation

shall f ully encapsulate the obstruction. The insulation shall

be in permanent contact with the underside of the

obstruction and prov ide an R-v alue of not less than R-19

between the obstruction and the unconditioned space below

the obstruction.

Method B:


The insulation shall be installed so that the required

thickness of insulation extends f rom the bottom edge of

the f loor f raming members up towards the subf loor

decking, prov ided that both of the f ollowing are installed:

1. Continuous insulation hav ing an R-v alue of not less

than R-5 is installed across the bottom edge of the f loor

f raming members, and supports the insulation within the

f loor cav ities.

2. Any exterior rim joists or exterior wall sheathing exposed

to f loor f raming cav ities shall be prov ided with insulation

hav ing an R-v alue of not less than that required f or the

exterior walls of the building, f or the f ull height of the f loor

f raming cav ity .







Narrow cav ities





conditioned spaces.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Floor systems over unconditioned spaces are notoriously dif f icult to insulate so they perform to meet the occupant's expectation and theeff iciency goals of the code. This proposal begins by ensuring that all f loor systems over unconditioned spaces are clearly defined. Next, f loor systemsbeing w alls that are laid f lat, this proposal ensures that a continuous air barrier system is incorporated w ith in the components of the buildings thermal



envelope created by the f loor system. Lastly, the proposal ensues that batt insulation is not overly compressed by stay w ire used to hold the insulationagainst the surface it is intended to insulate (the subfloor). In addition, the proposal clarif ies how to build a f loor system that performs w ell w henobstructions, such as ducts, are installed in the system. Option A describes the w ay the code traditionally has dealt w ith obstructions in the prescriptivepath utilizing footnote "G" of the R-value table R402.1.2. Option B better explains Joe Lstiburek' s codif ied method (since the 2015 IECC) of allow ing aspace for the obstruction betw een the insulation and the subfloor if continuous insulation is installed on the underside of the f loor system and insulation fully extends from the bottom to the top of all vertical perimeter f loor framing members.See attached detail from the City of Fort Collins for option A

Cost Impact: Will not increase the cost of constructionThis proposal w ould not add additional cost as it merely more clearly describes w hat is already required.


RE79-16Table R202 (New) [N1101.6 (New)], Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R202 (N1101.6) ENCAPSULATED. Where insulation has been surrounded on all sides by a continuous air barrier.

Revise as follows:








material.

Ceiling/attic







Walls



be sealed.










Rim joists Rim joists shall include thean air barrier.The insulation f or rim joists ishall be

encapsulated insulated.




insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: Insulation traps pockets of air, and the stagnate pocket or air retards the f low of heat from w arm to cold. If air permeable insulation it notencapsulated it cannot trap a stagnate pocket of air. More often than not, rim joist insulation is installed w ithout being encapsulated. This section ofcode is clarif ied by this proposal as it takes aw ay confusion by clearly stating that an air barrier is needed for air tightness and encapsulation is neededfor the insulation to function. In the past, most did not know w hat to do. Batts w ere placed in the rim joist and that component of the buildings thermalenvelope continued to be w eak.

Encapsulated: Reason Statement:

Six sided encapsulation has become the terminology that is used by inspectors to explain to builders and insulators how air permeable insulation needsto be installed inside of building cavities. The code as w ell as programs such as EnergyStar have been defining and requiring cavity insulation installsthat are encapsulated on all six sides for years now . Examples from IECC table R402.4.1.1 include the requirement to install an air barrier behind a tubor f ireplace on an exterior w all. In these applications, w here the dryw all is not continuously run in alignment w ith the air permeable insulation, additionalair barrier installation is needed to get encapsulation of the insulation. Why is this needed? Insulation creates its ability to retard the movement of heatby trapping pockets of air. By encapsulating the insulation in a six sided cavity insulation is able to create a stagnate pocket of air that functions as themanufacture intended to retard heat f low .

Cost Impact: Will increase the cost of constructionThere is likely to be a small cost implication w ith this proposal as Builders determine the most cost effective w ay to encapsulate the insulation in the rimjoist. The easiest w ay to achieve this w ould be to use blow n foam but more cost effective means w ill be developed as builders and insulatorsconcentrate on the issue. It is expected that the short term cost impact w ould be betw een $100- 500 as the average cost of spray foam is $1/linealsqft. If there is 200 feet of rim joist that w ould be $200.











material.

Ceiling/attic







Walls



be sealed.










Comply with narrow cav ity requirements





insulation.














Narrow cav ities





conditioned spaces.







Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: The space betw een the w indow sash and the framing of the w indow creates a small narrow cavity that needs to be insulated and airsealed. Low expansion foam can be an insulation and an air sealing strategy, but some prefer to chink the w indow w ith f ibrous insulation and then toair seal the cavity w ith caulking. This proposal adds f lexibility to how this detail is able to be achieved. In addition, this proposal adds criteria to apreviously empty box ensuring that it is clear that there are both air barrier and insulation criteria that need to be addressed w ith w indow , skylight, anddoor openings.

Cost Impact: Will not increase the cost of constructionThere are no cost implications associated w ith this proposal as it is merely clarifying w hat is required to happen in the space betw een the w indowframe and the w indow framing opening. In most cases low expansion foam is used to seal the gap betw een the framing and the w indow w hich w ouldalso be an insulation practice that is required by the narrow cavity section of this table. This proposal clarif ies that both air sealing and insulation needto be addressed in this location.


RE81-16R202 (New) [IRC N1101.6 (New)], Table R402.4.1.1 )IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])



Revise as follows:








material.

Ceiling/attic







Walls


The junction of the rim board to the sill plate and the subf loor

shall be sealed.

The junction of the bottom plate to the subf loor on exterior

walls shall be sealed

The junction of the top plate and dry wall adjacent to

unconditioned spaces the top of exterior walls shall be sealed.

Knee walls shall be encapsulated and sealed.













insulation.














Narrow cav ities







conditioned spaces.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


Reason: DOE Building America and other studies continually demonstrate that air sealing of the specif ic w all components added in this proposal help toensure a tight enclosure. In order to reach the code required air leakage targets more specif ic direction needs to be given in this table w ith regards tothe criteria that is required to seal. We are seeing that air tightness is not only important to attain our goals of durability, comfort, health and safety, asw ell as eff iciency, but is achievable w hen more clear and precise direction is given.

New DefinitionEncapsulated: Where insulation has been surrounded on all sides by a continuous air barrier.

Six sided encapsulation has become the terminology that is used by inspectors to explain to builders and insulators how air permeable insulation needsto be installed inside of building cavities. The code as w ell as programs such as EnergyStar have been defining and requiring cavity insulation installsthat are encapsulated on all six sides for years now . Examples from IECC table R402.4.1.1 include the requirement to install an air barrier behind a tubor f ireplace on an exterior w all. In these applications, w here the dryw all is not continuously run in alignment w ith the air permeable insulation, additionalair barrier installation is needed to get encapsulation of the insulation. Why is this needed? Insulation creates its ability to retard the movement of heatby trapping pockets of air. By encapsulating the insulation in a six sided cavity insulation is able to create a stagnate pocket of air that functions as themanufacture intended to retard heat f low .

Cost Impact: Will increase the cost of constructionThe code requires that the home is air tight and these are the areas of the home that specif ically help ensure that the level of tightness is achievable.Therefore cost increases associated w ith this proposal should be minimal as these features w ill be part of a total air sealing package that is alreadyhappening. That being said, the clarif ications of the required areas to be sealed, point out areas that have not been addressed w ell due to the poorlanguage previously used and therefore some cost increase w ill be caused by this proposal. It is estimated that the cost for materials and labor w ouldbe in the $50 - $150 range and the benefit w ould be consistent passage of the air leakage requirements of this code.


RE82-16R202 (New) (IRC N1101.6 (New)], Table R402.4.1.1 (IRC Table N1102.4.1.1)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])



R202 (N1101.6) GRADE 1 INSULATION INSTALLATION. An insulation installation method defined in the RESNET/ICCStandard 301 that aligns with all manufacturer's installation instructions to limit the reduction in R-value caused by poorinstallation of the insulation system.

Revise as follows:

TABLE R402.4.1.1 (N1102.4.1.1))AIR BARRIER AND INSULATION INSTALLATION



A continuous air barrier shall be installed in the

building's thermal env elope.

The exterior thermal env elope contains a continuous air

barrier.

Breaks or joints in the air barrier shall be sealed.

A continuous air barrier shall be prov ided throughout the

building thermal envelope. The air barriers shall be located on

the inside or outside of the building env elope, within the

assemblies comprising the env elope, or any combination

thereof .


material.

Air- permeable insulation shall be encapsulated inside an air

barrierᵇ.

All insulation installation shall be in accordance with

manuf acturer instructions and Grade 1 insulation

installation to limit the reduction of R-v alue.

Verif ication and certif ication of insulation installation shall

be in accordance with Section R303

Ceiling/attic







Walls



be sealed.














insulation.















Narrow cav ities





conditioned spaces.





Plumbing and wiring




piping and wiring.




insulated.










walls or ceilings.


b. Insulation shall not be required to be encapsulated in unconditioned attic spaces.

Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ANSI/RESNET/ICC 301-2014 Standard for the Calculation and Labeling of the Energy Performance of Low-Rise ResidentialBuildings using the HERS Index, March 7, 2014 (Republished January 15, 2016)Reason: Air barrier CriteriaAir barriers are not necessarily one component of the thermal envelope and may not be located in one location. The continuous air barrier locationlanguage is brought over from C402.5.1 to help better define that air barriers are part of an assembly that can be located anyw here in the assembly.

Insulation Installation Criteria

The term encapsulated is defined below . It is a term that is easily understood and one that ensure air barrier and thermal barrier alignment. SimilarlyGrade 1 installation is becoming a nationally acceptable w ay of quickly and easily explaining how insulation needs to be installed in accordance w ithmanufacturing instructions. In addition is offers additional guidance for modeling of the insulation for section R405 and R406.

We are seeing more insulation installation methods being developed that do not properly mark the R-value of the material. Therefore, it becomes moreimportant that the R-value of the installed insulation is certif ied by the installer w ho is the only one w ho often know s the installed R-value of thematerial. Documentation needs to be provided for inspection.

EncapsulatedSix sided encapsulation has become the terminology that is used by inspectors to explain to builders and insulators how air permeable insulation needsto be installed inside of building cavities. The code as w ell as programs such as EnergyStar have been defining and requiring cavity insulation installsthat are encapsulated on all six sides for years now . Examples from IECC table R402.4.1.1 include the requirement to install an air barrier behind a tubor f ireplace on an exterior w all. In these applications, w here the dryw all is not continuously run in alignment w ith the air permeable insulation, additionalair barrier installation is needed to get encapsulation of the insulation. Why is this needed? Insulation creates its ability to retard the movement of heatby trapping pockets of air. By encapsulating the insulation in a six sided cavity insulation is able to create a stagnate pocket of air that functions as themanufacture intended to retard heat f low .

Grade 1 Insulation Installation



Few if any code off icials, Builders, or installers read the manufactures instructions for how to install insulation. Yet, w ith regard to how insulation isinstalled, the sole requirement w ithin the IRC and the IECC is that insulation be installed in accordance w ith manufacture instructions. The RESENTstandard for insulation installation is being used in the f iled as a quick and understandable w ay of relating how insulation needs to be installed. Thestandard, in alignment w ith manufacture instructions, simply lays out the important aspects of manufacture instructions and recaps them in amanageable w ay. What the standard really adds is a means to quantify if the installation has met the installation requirements. This qualif ication pointsout that insulation does not have to be installed absolutely perfectly but it does need to be installed perrty darn w ell in order for it to w ork as intended bythe code. So w hen a f ield superintended or insulator hears that the insulation has not or has been installed to a Grade 1 they know right aw ay w hat ismeant. Lastly, Grade 1 offers modeling guidance for Energy Raters w ho are implementing Section R406 the Energy Rating Index path of the code.

RESENT Grade 1 - from RESNET/ANSI Standard 301-2014

"Grade I" shall be used to describe insulation that is generally installed according to manufacturer's instructions and/or industry standards. A "Grade I"installation requires that the insulation material uniformly f ills each cavity side-to-side and top-to-bottom, w ithout substantial gaps or voids aroundobstructions (such as blocking or bridging), and is split, installed, and/or f itted tightly around w iring and other services in the cavity.

To inspect, probe in, around, or through the insulation and/or vapor retarder in several places to see w hether these requirements are met. Replace orrepair the vapor retarder and insulation as necessary. During inspection (typically before dryw all is installed), if the exterior sheathing is visible from thebuilding interior through gaps in the cavity insulation material, it is not considered a "Grade I" installation.

To attain a rating of "Grade I", w all insulation shall be enclosed on all six sides, and shall be in substantial contact w ith the sheathing material on at leastone side (interior or exterior) of the cavity.

Exception: the interior sheathing/enclosure material is optional in climate zones 1-3, provided insulation is adequately supported and meets all otherrequirements.

For rim or band joist insulation, use the inspection guidelines under "Walls—Insulation value" to assess "Grade I", "Grade II", or "Grade III" installation.

Exception: the interior sheathing/enclosure material is optional in all climate zones, provided insulation is adequately supported and meets all otherrequirements.

For exterior applications of rigid insulation, insulation shall be in f irm contact w ith the structural sheathing materials, and tightly f itted at joints to beconsidered a "Grade I" installation.

For faced batt insulation, Grade I can be designated for side-stapled tabs, provided the tabs are stapled neatly (no buckling), and provided the batt isonly compressed at the edges of each cavity, to the depth of the tab itself, and provided it meets the other requirements of Grade I.

For sprayed or blow n-in products, density shall be suff icient that the f ill material springs back w hen compressed slightly w ith a hand or f inger, andprovided it meets the other requirements of Grade I.

Cost Impact: Will not increase the cost of constructionThe code requirement of this section are not changing, rather the language clarif ies the intent of the current code and offers more direction on how tosuccessfully implement w hat is being asked for through manufactures instructions.

Analysis: A review of the standard(s) proposed for inclusion in the code, ANSI/RESNET/ICC 301-2014 (Republished January 15, 2016), w ith regard tothe ICC criteria for referenced standards (Section 3.6 of CP#28) w ill be posted on the ICC w ebsite on or before April 1, 2016.


RE83-16 : R402.4.1.2-MAKELA12639

RE83-16R402.4.1.2 (IRC N1102.4.1.2)Proponent : Eric Makela, Cadmus Group, representing RESNET


R402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones 3 through 8.Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 BRS/RESNET/ICC 380 and reported at apressure of 0.2 inch w.g. (50 Pascals). Where required by the code official, testing shall be conducted by an approved thirdparty. A written report of the results of the test shall be signed by the party conducting the test and provided to the codeofficial. Testing shall be performed at any time after creation of all penetrations of the building thermal envelope.

During testing:




Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: BRS/RESNET/ICC 380-2016 Standard for Testing Airtightness of Building Enclosures, Airtightness of Heating and Cooling AirDistribution Systems, and Airflow of Mechanical Ventilation Systems. Republished January 2016. Addendum A-2015 andAddendum B-2015.

Reason: BSR/RESNET/ICC 380-2016 provides needed guidance for performing envelope air leakage, duct leakage and air f low testing. Building off ofexisting standards (e.g. ASTM E779-10) the standard allow s for multiple test procedures to provide f lexibility for the testing industry. Standard 380 alsocovers testing for single-family and 3-story and less multi-family projects and w ill be referenced as the protocol for testing for the rating industry. The E779 standard requires multi-point testing under both pressurized and depressurized conditions. BSR/RESNET/ICC 380-2016 allow s E 779 tests butexpands the test methodology to allow single point tests under only one pressurization/depressurization condition and includes correction factors toaccount for test bias and uncertainty. Thus, 380 can be a substantially less expensive protocol than E 779.The standard provides a consistent, uniform methodology for evaluating the airtightness of building envelopes and heating and cooling air ducts. Thetest procedures can be used as building diagnostics, in quality assurance and control, for determining compliance w ith codes and standards and todetermine input to energy simulations and ratings. The standard provides a step-by-step approach to testing for building envelop leakage w ith the goalof standardizing how testing should performed in the f ield.Standard 380 provides guidelines for calculating common air leakage testing metrics e.g. CFM50, ACH50, NLA, SLA and ELA. Referencing a standardw ith this type of f lexibility allow s the testing metric to change in the code w ithout the need to change the reference standard (e.g. changing from ACH50to SLA).

Why Use BSR/RESNET/ICC 380-2016 in Place of ASTM Standard E779-10. ASTM Standard E779-10 requires multi-point testing at a range of 10 to 60 Pain 5 to 10 Pa increments using both pressurization AND depressurization of the building and the reporting requirements include: fan pressurizationmeasurements (inside-outside zero f low building pressure differences), inside and outside temperatures (at start and end of test), the product of theabsolute value of the indoor/outdoor air temperature difference multiplied by the building height, tabular list of all air leakage measurements andcalculations (time, building pressure difference, air density, nominal airf low , fan airf low rate, air leakage rate, deviations from standard procedure, w indspeed and direction and w hether it is estimated or measured on site (if measured on site, the height above ground at w hich the w ind speed w asmeasured), and the calculation details (leakage coeff icient, pressure exponent, effective leakage area for pressurization and depressurization andcombined results, w hether a reference pressure other than 4 Pa w as used, and an estimate of confidence limits). This is a test method more suitablefor research testing than code enforcement, so w e adopted BSR/RESNET/ICC 380-2016 w ith references to specif ic calculation procedures found inASTM Standard E779-10.BSR/RESNET/ICC 380-2016 has been developed to provide a consensus national standard for consistent measurement of several air-f low relatedresidential building metrics. It builds off of existing American National Standards to provide standard procedures essential to the evaluation of the energyperformance of residential buildings energy.

Cost Impact: Will not increase the cost of constructionRESNET Standard 380 allow s for single point testing to demonstrate compliance w ith the air leakage requirements verses multi-point testing nowrequired by E 779. The results of the tw o tests, as decribed in the reason statement, are comparable so that a house constructed to meet the E 779standard w ill cost no different than a house constructed to meet Standard 380. The code change may lead to a reduction in the costs to conduct thetests as the envelope testing industry may charge more for a multi-point test than a single-point test given the time needed for the multi-point test.

Analysis: A review of the standard proposed for inclusion in the code, BRS/RESNET/ICC 380-2016, w ith regard to the ICC criteria for referencedstandards (Section 3.6 of CP#28) w ill be posted on the ICC w ebsite on or before April 1, 2016)


RE84-16 : R402.4.1.2-MOORE11094

RE84-16R402.4.1.2 (IRC N1102.4.1.2)Proponent : Mike Moore, Newport, representing Broan-NuTone ([email protected])


R402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones 3 through 8.Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written report of theresults of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performedat any time after creation of all penetrations of the building thermal envelope.

During testing:



3. Interior doors, if installed at the time of the test, shall be open.4. Exterior doors or interior terminations for continuous ventilation systems and heat recovery ventilators shall be

closed and sealed.5. Heating and cooling systems, if installed at the time of the test, shall be turned off.6. Supply and return registers, if installed at the time of the test, shall be fully open.

Reason: This change provides clarif ication and f lexibility to the current requirement as follow s, w ithout reducing stringency:1. Replace the reference to "doors" w ith a reference to "terminations". Residential ventilation systems do not have doors.

2. Permit interior or exterior terminations to be sealed. This increases f lexibility and can promote safety w hile reducing time and costs.

3. Remove the reference to "heat recovery ventilators". HRVs are a type of ventilation system, so the reference here is redundant.

4. Remove the requirement to "close" the termination. This is not necessary if the termination is sealed.

Cost Impact: Will not increase the cost of constructionThis change increases f lexibility for conducting the blow er door test and can potentially reduce associated costs.


RE85-16R202 [IRC N1101.6], R402.4.1.2 [IRC N1102.4.1.2]Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R202 (N1101.6) DWELLING UNIT ENCLOSURE AREA The total shell area of the dwelling unit's basement walls, exteriorwalls, floors, ceilings, roofs and any other building elements assemblies that enclose a dwelling unit or provides a boundarybetween a dwelling unit's conditioned space and unconditioned space or an adjacent dwelling unit's conditioned space.

Revise as follows:

R402.4.1.2 (N1102.4.1.2) Testing. The buildingDetached buildings or dwelling unit units shall be tested and verified as having an air leakage rate not exceeding five 1.1 squareinches equivalent leakage area/100 square feet of dwelling unit enclosure area (ELA/100sqft of shell area).

Attached buildings or dwelling units shall be tested and verified as having an air changes per hour in Climate Zones 1 and 2,and three air changes per hour in Climate Zones 3 through 8 leakage rate not exceeding 1.3 square inches equivalent leakagearea (Area/100 square feet of dwelling unit enclosure area (ELA/100sqft of shell area).

Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written report of theresults of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performedat any time after creation of all penetrations of the building thermal envelope.

During testing:




Reason: This proposal is tackling three issues. First, it recognizes the fact that tight housing, regardless of the climate zone the home is built in, isimportant. Tight houses ensure control and predictability of the air in the home w hich benefits durability, comfort, and eff iciency (the complete intent ofthe code) in the house regardless of w hether the house is built in cooling or heating dominated climates. Eff iciency use of heating and cooling energy isimportant.

Second, the reality is that the current air leakage measurement, ACH50, penalized attached housing and smaller houses due to its being based on housevolume size. The proposed new matrix for compliance, ELA/100sqft of shell area, eliminates volume from the equation and therefore the bias againstsmall houses and apartment units. In addition, attached housing is treated more fairly as this standard of measurement incorporates leakage throughadiabatic w alls, ceilings, and f loors. Thus compartmentalization, as w ell as air leakage to the outdoors, is promoted and ensured.

Third, Separate air leakage targets have been developed for attached (single family) homes and attached housing in order to f irst recognize thediff iculty in attaining the current levels of required air tightness for attached housing, and second to offer an air leakage target for both attached anddetached housing that is attainable and creates a w ell performing, tight, energy eff icient home. Both targets are in alignment w ith the energy savinggoals of the IECC.

The data set used to evaluate w here to set the air leakage ELA/100sqft target show s that setting the number at 1.3 square inches per 100 sqft of shellarea for attached housing w ill offer a more reasonable but still impactful target equivalent to the 5 ACH target currently in place for climate zones 1 and2. For detached housing the target of 1.1 is in alignment w ith the current level of achievable air tightness for single family homes.

Our data is also show ing that detached homes are consistently performing bellow 1.1 ELA/100 (3 ACH50) and that attached homes are currentlyaveraging at 3.52 ACH50 or better than 1.3 ELA/100

Detached target:

1.1(ELA/100)x3 (ach50)/1.09 (ELA/100) = 3.03 ACH 50

Attached target

1.3(ELA/100) x 4.93(ach50)/1.3 (ELA/100) = 4.93 ACH 50

See attached data


Cost Impact: Will increase the cost of constructionCost of construction in climate zones 1 and 2 is expected to go up due to this proposal but w ill not go up in climate zones 3 - 8 as the leakage targetsare essentially the same as currently in place. The proposal is merely changing the reporting matrix. Warmer climate zone builders w ill gain eff iciencyand performance benefits but cost w ill increase as they learn to tighten their building envelopes from the 2015 IECC requirements of 5 ACH50 to w hatw ould be required by this proposal w hich is approximately 3 ACH50. It is estimated that the cost increase to tighten the building envelope in climatezones 1 and 2 to those levels required in climate zones 3-8 w ould be small as section R402.4.1.1 currently requires that the items listed in tableR402.4.1.1 be carried out in all climate zones. The reality is that they are not, but assuming that they should, it is estimated that the construction costw ould increase betw een $1000 - $2000, only in climate zones 1 and 2 to bring them in par w ith the rest of the nation.


RE85-16 : R402.4.1.2-SCHWARZ13480


RE86-16R402.4.1.2.1 (New) [IRC N1102.4.1.2.1 (New)]Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])

2015 International Energy Conservation CodeR402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones 3 through 8.Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written report of theresults of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performedat any time after creation of all penetrations of the building thermal envelope.

During testing:





R402.4.1.2.1 (N1102.4.1.2.1) Testing garage separation. Testing shall be performed to ensure that an attached garage isseparated from the house.

1. While conducting the air leakage test as described in Section R402.4.1.2 the separation between the house andthe garage shall be tested to ensure that the house in reference to the garage is not less than 45 pascals ofpressure when the house is held at 50 Pascals of pressure in relationship to outside. All operable garage openingsto the outside shall be closed during this test.

2. The test required by Item 1 shall be repeated with the overhead garage door open, The test shall verify that theresults are not more than 6 percent higher than the original results.

Reason: The energy code like all code is about health, safety, comfort, durability, as w ell as eff iciency. The garage is the largest source of pollutantsand carbon monoxide in the house and it has been codif ied in table R402.4.1.1 to ensure that the garage is air sealed and separated from the house. Unfortunately, as is the case in most situations, there is no w ay to be sure that separation has been achieved, in this location, unless that separationhas been tested. Fortunately testing for separation betw een the house and garage is very simple and is made even more practical due to the mandatedblow er door test for every house.

To ensure that there are not false positive results of the test Building America research has determined that the test requires tw o steps to ensure that afalse positive does not reveal itself in the f irst step. First, w hile the house is at 50 Pascals of pressure w ith regards to outside during the blow er doortest a zonal pressure test is performed by installing a tube betw een the house and the garage. (Usually under the door betw een the house and thegarage) If the garage is clearly outside, the measurement betw een the house and the garage should also be 50 Pascals of pressure. The closer themeasurement is to zero the more connected the garage is to the house. This test is performed w hen all opening betw een the garage and the outsideare closed. Second, this test is repeated w ith the overhead vehicle door open. If the results of the second test are greater than 6% the connectionbetw een the house and the garage tests fails.

If w e continue to mandate separation betw een the house and the garage w e must also test for it to ensure that the health and safety intent of the codeis maintained. Programs such as the EPA Indoor Air Plus and the DOE Zero Energy Ready Home program have incorporated protocols to test for thisseparation. In addition, Jurisdictions around the country, such as Fort Collins Colorado have amended the IECC to require this test.

People have asked if this is really an issue. The problem is that one cannot know unless one tests. The complexities of the assemblies separating thehouse and the garage, w ith dropped ceilings, pipe, ducts, w iring and w ho know s w hat else penetrating the buildings thermal envelope and air barriersystems, make it an extremely dif f icult part of the house to seal. What w e do know is that automobiles are the largest source of carbon monoxide in ourhome and they are parked in attached garages. We also know that other pollutants such as gasoline, pesticides and paints are stored in attachedgarages. Therefore, to not test is clearly against the health and safety intent of the code and ultimately places builders and homebuyers at risk. Lastly,there a numerous studies that have documented that pollutants from the garage are capable of migrating into the house. This test w ill ensure that thispossibility is lessoned,

Bibliography: Resources:US Department of Energy Building Technologies Off ice

Building America Program

"Air Leakage and Air Transfer betw een Garage and Living Space"

Armin Rudd Building Science Corporation

September 2014

EnergyLogic Study:

EnergyLogic tested 344 homes of w hich 145 passed this test and 199 failed. This indicates that 59% of the homes failed to fully separate the housefrom the garage. These homes w ere tested as part of an existing home audit program. The age of the homes varied w idely but this study is an


RE86-16 : R402.4.1.2-SCHWARZ13050

indication of the historic dif f iculty is separating the house from the garage.

Cost Impact: Will increase the cost of constructionThe cost implication of this proposal is small as this test must be performed at the same time as the blow er door test described in section R4052.4.1.2.The garage separation test w ill add approximately 15 minutes to the testing that is already being performed so may add betw een $25 and $50. If thetest fails it is an indication that already required code air sealing scopes of w ork are not being performed properly. This should require greater attentionto detail rather than additional cost from the air sealing contractor.


RE87-16R402.4.1.2 (IRC N1102.4.1.2), Table R405.5.2(1) [IRC Table N1102.5.2(1)]Proponent : Donald Surrena, National Association of Home Builders ([email protected])


R402.4.1.2 (N1102.4.1.2) Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate notexceeding five air changes per hour in Climate Zones 1 and 2, and three four air changes per hour in Climate Zones 3 through8. Testing shall be conducted in accordance with ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50Pascals). Where required by the code official, testing shall be conducted by an approved third party. A written report of theresults of the test shall be signed by the party conducting the test and provided to the code official. Testing shall be performedat any time after creation of all penetrations of the building thermal envelope.

During testing:




TABLE R405.5.2 (1) [N1105.5.2 (1)]SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS


Air exchange rate

Air leakage rate of 5 air changes per hour in climate zones 1 and 2 and34 air changes in climate zones 3 through 8 at a pressure of 0.2

inches w.g. (50Pa). The mechanical v entilation rate shall be in additionto the air leakage rate and the same asa in the proposed design, but

no greater than 0.01 x CFA + 7.5 x (Nbr +1)where:

CFA = conditioned f loor areaNbr = number of bedrooms

Energy recov ery shall not be assumed f or mechanicalv entilation.

For residences that are not tested, the same air leakage rate as thestandard ref erence design. For tested residences the measured air

exchange ratea.

The mechanical v entilation rated shall be in addition to the airleakage rate and shall be as proposed.


None, except where mechanical v entilation is specif ied by theproposed design, in which case:Annual v ent f an energy use:kWh/y r =

0.03942 × CFA + 29.565 × (Nbr +1)where:CFA = conditioned f loorareaNbr = number of bedrooms

As proposed

Internal gains IGain = 17,900 + 23.8 × CFA + 4104 × Nbr (Btu/day per dwelling unit) Same as standard ref erence design.

Internal mass An internal mass f or f urniture and contents of 8 pounds per squaref oot of f loor area.


specif ically designed as a thermal storage elementc but not integralto the building env elope or structure.

Structural mass

For masonry f loor slabs, 80 percent of f loor area cov ered by R-2carpet and pad, and 20 percent of f loor directly exposed to room air. As proposed

For masonry basement walls, as proposed, but with insulation requiredby Table R402.1.4 located on the interior side of the walls As proposed

For other walls, f or ceilings, f loors, and interior walls, wood f rameconstruction As proposed


As proposed f or other than electric heating without a heat pump, wherethe proposed design utilizes electric heating without a heat pump thestandard ref erence design shall be an air source heat pump meeting

the requirements of Section C403 of the IECC-CommercialProv isions.Capacity : sized in accordance with Section R403.7

As proposed

Cooling sy stemsd, f As proposed Capacity : sized in accordance with Section R403.7. As proposed

Serv ice water heatingd, e, f , g As proposed Use: same as proposed design

As proposed gal/day = 30 + (10 × Nbr )

Thermal distribution sy stems

Duct insulation: From Section R403.2.1A thermal distribution sy stemef f iciency (DSE) of 0.88 shall be applied to both the heating and

cooling sy stem ef f iciencies f or all sy stems other than tested ductsy stems. For tested duct sy stems, the leakage rate shall be 4 cf m

(113.3 L/min) per 100 f t2 (9.29 m2 ) of conditionedfloor area at apressure of dif f erential of 0.1 inches w.g. (25 Pa).

As tested or as specif ied in Table R405.5.2(2) if not tested. Ductinsulation shall be as proposed.

Thermostat Ty pe: Manual, cooling temperature setpoint = 75°F; Heatingtemperature setpoint = 72°F Same as standard ref erence







e. For a proposed design without a proposed heating sy stem, a heating sy stem with the prev ailing f ederal minimum ef f iciency shall be assumed f or both the standardref erence design and proposed design.f . For a proposed design home without a proposed cooling sy stem, an electric air conditioner with the prev ailing f ederal minimum ef f iciency shall be assumed f or both thestandard ref erence design and the proposed design.



Reason: Building tightness is an important part of an energy-eff icient and comfortable house. How ever, 3 air changes(ACH) per hour at 50 Pascals isan extremely low target tightness, especially for smaller homes. The ASHRAE Handbook of Fundamentals show s that around 8% of U.S. homesachieve 3 ACH or less, 13% achieve 4 and less than 23% achieve 5. The proposed 5 ACH w hile still an aggressive tightness level w ill provide a tight,comfortable, energy-eff icient home. To further show the stringency of this requirement, 12 of 16 states have amended the tightness requirement.

1. Delaw are – amended2. DC- amended3. Idaho- amended4. Illinois- amended5. Iow a- amended6. Maryland- NO7. Massachusetts- NO8. Minnesota- NO9. Montana- amended

10. Nevada- amended11. New Jersey- NO12. Rhode Island- amended13. Utah- amended14. Vermont- amended15. Virginia- amended16. Washington- amended

DOE has verif ied that achieving 3 ACH50 is problematic, even in Maryland w ho has had a 3 ACH requirement for over 3 years (see chart below ).


RE87-16 : R402.4.1.2-SURRENA12456

Cost Impact: Will not increase the cost of constructionThe code change proposal reduces stringency to avoid extra costs for not being able to comply w ith the requirements that 12 of 16 states have alreadyamended to reduce costs.


RE89-16 : R402.4.2-COLLINS11559

RE89-16R402.4.2 (IRC N1102.4.2)Proponent : David Collins, representing Sustainability, Energy, High Performance Code Action Committee


R402.4.2 (N1102.4.2) Fireplaces. New wood-burning fireplaces shall have tight-fitting flue dampers or doors, and outdoorcombustion air. Where using tight-fitting doors on factory-built fireplaces listed and labeled in accordance with UL 127, thedoors shall be tested and listed for the fireplace in accordance with UL 127. Where using tight-fitting doors on masonryfireplaces, the doors shall be listed and labeled in accordance with UL 907.

Reason: The existing text is poorly structured and it implies that the f ireplaces are listed and labeled in accordance w ith UL127. The standard appliesto the doors and not the f ireplaces.This proposal w as submitted by the ICC Sustainability Energy and High Performance Code Action Committee (SEHPCAC). The SEHPCAC w asestablished by the ICC Board of Directors to pursue opportunities to improve and enhance International Codes w ith regard to sustainability, energy andhigh performance as it relates to the built environment included, but not limited to, how these criteria relate to the International Green Construction Code(IgCC) and the International Energy Conservation Code (IECC). In 2015, the SEHPCAC has held three tw o- or three-day open meetings and 25w orkgroup calls, w hich included members of the SEHPCAC as w ell as any interested parties, to discuss and debate proposed changes and publiccomments. Related documentation and reports are posted on the SEHPCAC w ebsite at: http://w w w .iccsafe.org/cs/SEHPCAC/Pages/default.aspx

Cost Impact: Will not increase the cost of constructionThe proposal is an editorial clarif ication. It has no impact on the technical requirements of the code and therefore w ill not affect cost.



RE90-16 : R402.4.2-STROUD12604

RE90-16R402.4.2 (IRC N1102.4.2)Proponent : Tom Stroud, Hearth, Patio & Barbecue Association, representing Hearth, Patio & Barbecue Association([email protected])


R402.4.2 (N1102.4.2) Fireplaces. New wood-burning fireplaces shall have tight-fitting flue dampers or doors, and outdoorcombustion air. Where using tight-fitting doors on factory-built fireplaces listed and labeled in accordance with UL 127, thedoors shall be tested and listed for the fireplace. Where using tight-fitting doors on masonry fireplaces, the doors shall be listedand labeled in accordance with UL 907.

Reason: UL 907 is not a useful standard for the purpose of this code requirement. There are no f ireplace doors certif ied to that standard and,according to testing laboratories, there is no w ay to test to that standard. The biggest dif f iculty is that the masonry f ireplace must be brought up toequilibrium, w hich is not achievable.The intent of this code is ensure a better seal on the appliances, thereby decreasing air inf iltration and exfiltration. While seeking to require the use oftight-f itting doors on masonry f ireplaces w ould seem to help accomplish that goal, having a test standard that is unachievable w ill actually limit, orpossibly eliminate, the installation of doors.

Cost Impact: Will not increase the cost of constructionThis proposal w ill low er costs dow n by not having a requirement for a product to meet a non-usable, non-useful standard.


RE91-16 : R402.4.4-CONNER12720

RE91-16R402.4.4 (IRC N1102.4.4)Proponent : Craig Conner ([email protected]); Brent Ursenbach, Salt Lake County, representing Utah Chapter ICC([email protected])


R402.4.4 (N1102.4.4) Rooms containing fuel-burning appliances. In Climate Zones 3 through 8, where open combustionair ducts intake openings provide combustion air from outside conditioned space to open combustion fuel burning spaceheating or water heating appliances, the appliances and combustion air opening shall be located outside the building thermalenvelope or enclosed in a room, isolated from inside the thermal envelope. Such rooms shall be sealed and insulated inaccordance with the envelope requirements of Table R402.1.2, where the walls, floors and ceilings shall meet not less than thebasement wall R-value requirement. The door into the room shall be fully gasketed and any water lines and ducts in the roominsulated in accordance with Section R403. The combustion air duct shall be insulated where it passes through conditionedspace to a minimum of R-8.


Code.3. Intake openings that have a mechanical damper that opens only when appliance is operating.

Reason: Reason Statement:This modif ication improves the clarity of the existing language and makes it more usable. It also clarif ies that the code section only applies to combustionair that comes from outside. The requirement therefore w ould only apply to space heating and w ater heating appliances – not gas clothes dryers orgas stoves. It adds an exception for mechanical dampers.

Cost Impact: Will not increase the cost of constructionThis is only a clarif ication of the code. The technical requirements have not changed.


RE92-16 : R402.4.4-SURRENA12468

RE92-16R402.4.4 (N1102.4.4)Proponent : Donald Surrena ([email protected])


R402.4.4(N1102.4.4) Rooms containing fuel-burning appliances. In Climate Zones 3 through 8, where open combustionair ducts provide combustion air to open combustion fuel burning appliances, the appliances and combustion air opening shallbe located outside the building thermal envelope or enclosed in a room, isolated from inside the thermal envelope. Such roomsshall be sealed and insulated in accordance with the envelope requirements of Table R402.1.2, where the walls, floors andceilings shall meet not less than the basement wall R-value requirement. The door into the room shall be fully gasketed andany water lines and ducts in the room insulated in accordance with Section R403. The combustion air duct shall be insulatedwhere it passes through conditioned space to a minimum of R-8.


Code.

Reason: This w as a new section to the 2015 IECC and has proven to be confusing and is being misinterpreted.

No data w as show n verifying a problem existed No energy savings potential w as show n. No cost data w as provided to justify the increase to the cost of construction.A study w as done by Home Innovation Research Labs that f inds the cost of meeting this requirement w ould be $878 for a home w ith spaceheating or w ater heating equipment in the basement.

Cost Impact: Will not increase the cost of constructionThis proposal has the potential to reduce the cost of construction by not requiring unnecessary construction.


RE94-16 : R402.4.5-NORMAN11833



R402.4.5 (N1102.4.5) Recessed lighting. Recessed luminaires installed in the building thermal envelope building thermalenvelope shall be sealed to limit stop all air leakage between conditioned and unconditioned spaces. All recessed luminairesshall be IC-rated and labeledlabeled as having an air leakage rate not more than 2.0 cfm (0.944 L/s) when tested in accordancewith ASTM E 283 at a 1.57 psf (75 Pa) pressure differential airtight. All recessed luminaires shall be sealed with a gasket orcaulk between the housing and the interior wall or ceiling covering.

Reason: Any luminaire air leakage w hether in a manufactured can or in gaps of installation, is not allow ed by Table 402.4.1.1. This section must notcontradict the table.Zero leakage is a reasonable and easily attainable condition. Any allow ed leakage is not really measurable as test vs. a limit. Practical can lights, not air-tight in violation of the Table, may pass much less leakage than installation gaps not testable. I have never seen an airtight can installed airtight, but oftenw ith very large gaps not amenable to sealing w ith a silly foam gasket sometimes-found and never to survive for more than a few years in ineffectiveservice. Can light installers are often non-professional construction initiates, including untrained builders and homeow ners, and can not be relied uponto have a proper method and material of caulking. Foam caulks are never suitable for can to dryw all annuli. the correct sealing point. Many caulks w illnot bridge the found clearances, or are incompatible w ith texture and paint processes. Suitable caulk materials are available, as for example, my f lexiblegrout, readily available for freely-licensed manufacture or user preparation, alw ays-ready for the installer, w ith indefinite pot life and no-messw orkability as texture repair. There are possible sealing means for continued can installation. In a better future, w e w ill stop setting luminaires in cans. Inthis near future, low -voltage technicians, not licensed electricians, w ill install lights as 24 vdc push and pluck gems in pendants or airtight ceilingreceptacles, to serve forever. Advance to this future is helped by not fudging on stupid can lights.

Cost Impact: Will not increase the cost of constructionWe w ould not encourage a painter to economize by not using caulk. This sealing, of recessed light ceilingannuli, is not more diff icult or expensive.


http://plasterrepairhowto.blogspot.com/

RE95-16 : R402.5-CONNER12770

RE95-16R402.5 (IRC N1102.5)Proponent : Craig Conner ([email protected])


R402.5 Maximum fenestration U-factor and SHGC (Mandatory). The area-weighted average maximum fenestration U-factor permitted using tradeoffs from Section R402.1.5 or R405 shall be 0.48 in Climate Zones 4 and 5 and 0.40 in ClimateZones 6 through 8 for vertical fenestration, and 0.75 in Climate Zones 4 through 8 for skylights. The area-weighted averagemaximum fenestration SHGC permitted using tradeoffs from Section R405 in Climate Zones 1 through 3 shall be 0.50.

Reason: The limits on U-factor and SHGC trade offs reduce f lexibility w ithout any compensating energy savings. A decrease in the energy eff iciencyof the w indow s through the performance calculation w ould have to be made up elsew here leaving the resulting energy eff iciency, so the energy resultis neutral. This section also adds confusion. The numerical limit on trade offs is sometimes confused w ith the actual requirement itself (in Table R402.1.2).

Cost Impact: Will not increase the cost of constructionThis w ill not increase the cost of construction, as it adds no new requirements. The actual requirements are in Tables R402.1.2 and R402.1.4.


RE96-16 : R402.5-CULP12656

RE96-16R402.5 (IRC N1102.5)Proponent : Thomas Culp, Birch Point Consulting LLC, representing self ([email protected])


R402.5 (N1102.5) Maximum fenestration U-factor and SHGC (Mandatory). The area-weighted average maximumfenestration U-factor permitted using tradeoffs from Section R402.1.5 or R405 shall be 0.48 in Climate Zones 4 and 5 and 0.40in Climate Zones 6 through 8 for vertical fenestration, and 0.75 in Climate Zones 4 through 8 for skylights. The area-weightedaverage maximum fenestration SHGC permitted using tradeoffs from Section R405 in Climate Zones 1 through 3 shall be 0.50.

Reason: By definition, trade-offs are energy neutral, so these mandatory "hard limits" save no energy, but set artif icial constraints that limit designflexibility and innovation. Practically speaking, the vast majority of "normal" w indow s already meet these criteria, so this section has little real impact, andonly serves to (a) add confusion betw een these numbers and the real requirements in Table R402.1.1, and (b) cause compliance problems for uniqueor special applications.

DOE recently presented results from its residential energy code f ield study, w ith compliance data from Alabama, Kentucky, Maryland, North Carolina,Pennsylvania, and Texas. The results show ed that 99% of w indow s w ere compliant w ith the prescriptive U-factor requirements (and only 0.2% w erenot compliant w ith the hard caps), and 98% w ere compliant w ith the prescriptive SHGC requirements (and only 0.4% w ere not compliant w ith the hardcaps). In other w ords, w indow compliance is extremely high, the hard caps are doing nothing, and this w hole debate is moot.

This section does nothing but w aste space in the code, create artif icial barriers, and cause confusion and unnecessary headaches for code off icialsand builders. It should be removed.

Bibliography: Residential Energy Code Field Study, U.S. DOE Building Energy Codes Program, Webinar Dec 2015,https://w w w .energycodes.gov/sites/default/f iles/documents/Field_Study_120715_Final.pdf slides 40-47.

Cost Impact: Will not increase the cost of constructionField data show this section has almost no impact, so there is no impact on cost, and could decrease cost of construction by increasing f lexibility forsome special applications.


https://www.energycodes.gov/sites/default/files/documents/Field_Study_120715_Final.pdf

RE97-16 : R402.6 (NEW)-DAVIES13443

RE97-16R402.6 (New) [IRC N1102.6 (New)]Proponent : Don Davies, self ([email protected])


R402.6 (N1102.6) Exterior insulation for slab on grade floors (Mandatory) Slab on grade floors shall have insulationinstalled on the exterior of the vertical slab edge . The insulation shall extend to a depth not less that 24 inches (610 mm)below the top of the slab floor or to the bottom of the slab edge, whichever is less. The insulation shall have an R-value of notless than R-10.

Exceptions: Slab edge insulation shall not be required for either of the following:

1. Jurisdictions where the code official has designated the jurisdiction as having very heavy termite infestation.2. Buildings in climate zones 1, 2 or 3.

Reason: During the life expectancy of a dw elling, insulation can be added to envelope portions of the building. Doors and w indow s have a lifeexpectancy of about 30 years so they w ill be replaced w ith more energy eff icient items. Insulation on the roof can be added w hen the building is re-roofed in 20 years or additional insulation can be blow n into the attic. When the building gets exterior upgrades, insulation can be added as part of anEFIS, or the w alls can be furred out on the interior and insulation can be added. One envelope element w hich w ill not be changed or upgraded w ill be atthe slab on grade location. Adding the insulation later at the interior of the slab w ould be cost prohibitive. Adding insulation at the exterior at this locationw ould require removing the w alks, landings and landscaping and obviously, that is not going to happen. During construction, the cost of the slab-on-grade insulation is minimal and is factored into the overall performance of the envelope. Slab on grade insulation is alw ays needed as a thermal breakand should not be traded off for insulation elsew here.

Cost Impact: Will not increase the cost of constructionThere is no additional cost of constructions because the cost of the insulation at the slab-on-grade location is factored into the calculation of the overallbuilding envelope requiring less insulation elsew here in the building.


RE98-16 : R403.13 (NEW)-FOSTER13434

RE98-16R202, R403.13 (New) [IRC N1103.13 (New)]Proponent : Charles Foster, representing Steffes Corporation ([email protected])

2015 International Energy Conservation CodeR202 (N1101.6) GENERAL DEFINITIONS


ENERGY STORAGE SYSTEMEquipment that is designed for and capable of receiving, storing and discharging energy. Common examples of energy storagesystems include chemical batteries, flywheels, and thermal storage systems.


R403.13 (N1103.13) Energy storage Where an energy storage system is installed, the following information shall besubmitted to the code official:

1. A narrative describing the operation of the energy storage system including information such as the building end useloads being supplied by the energy storage system and the storage medium used. 2. A list of components of the energy storage system. 3. A calculation report that indicates the maximum charge level in kilowatt-hours (kWh), the maximum electric chargerate in kilowatts (kW) and the electric or thermal discharge rate in kilowatts (kW) of the system. 4. Identification of the utility, independent servce operator (ISO), or regional transmission organization (RTO) that willcontrol the energy storage system. 5. An indication of how the energy storage system is to be dispatched by the serving grid operator, or micro-grid operatorfor the purposes of frequency regulation, renewable integration, or grid stabilization.

Reason: This proposal w ould add specif ications for use of energy storage systems in a residence. Currently, no such specif ications are included inthe IECC.In the last code cycle, identical language w as approved for inclusion in the IGCC.

For additional information on energy storage:

See article at:http://w w w .pjm.com/about-pjm/exploring-tomorrow s-grid/electricity-storage.aspx?p=1 for information on the value of ETS in the PJMInterconnection service territory.

See article athttp://w w w .sustainablebusinessoregon.com/articles/2012/04/bonneville-pow er-calls-for-f irst -w ind.html?page=all for information onBonneville Pow er curtailment of w ind generation amounting to almost 100,000 MWH's in 2011.

See Kema Consulting report (Commissioned by the U.S. Department of Energy under the supervision of Sandia NationalLaboratory) noting signif icant reduction in carbon emissions at http://prod.sandia.gov/techlib/access-control.cgi/2008/088229.pdf.

See http://w w w .steffes.com/off-peak-heating/ets.html for more information on utility benefits of WTS, including energy savingsassociated w ith thermal storage and frequency regulation.

See Sandia National Laboratory w ebsite at http://w w w .sandia.gov/ess/ for information on the contributions of energy storage toelectric grid stability.

For a detailed description of frequency regulation in North America see Department of Energy / National Energy TechnologyLaboratory Report Frequency Instability Problems in North American Interconnections, DOE/NETL-2011/1473, Final Reportdated May 1, 2011 found at http://w w w .netl.doe.gov/energy-analyses/pubs/TransmissionFreqProb.pdf

Cost Impact: Will not increase the cost of constructionThis proposal does not add any requirements to the IECC and thus w ill not add to the cost of construction.


RE99-16 : R403.3 -DRUMHELLER12359

RE99-16R403.3 (IRC N1103.3), R403.3.6 (New) [IRC N1103.3.6 (New)]Proponent : Craig Drumheller ([email protected])


R403.3 Ducts. Ducts and air handlers shall be installed in accordance with Sections R403.3.1 through R403.3.5 R403.3.6.


R403.3.6 Ducts buried within ceiling insulation Supply and return ducts shall be permitted to be installed partially, or fullyburied within ceiling insulation provided the the ducts comply with all of the following:

1. Supply and return ducts shall be insulated with an R-value of not less than R-8.2, At all points along the duct, the sum of the ceiling insulation R-values above the top of the duct and below the bottomof the duct shall be not less than R-18 excluding the duct R-valu.3, In Climate Zones 1A, 2A, 3A, where supply ducts are completely covered with ceiling insulation, the supply ductsshall be insulated to an R-value of not less than R-18 and the ducts shall be in accordance with the vapor retarderrequirements in Section 604.11 of the International Mechanical Code or Section M1601.4.6 of the International ResidentialCode as applicable.

Exception: Sections of supply ducts less than 3 feet from the supply outlet.

Reason: A signif icant amount of research has been performed on ducts buried in attic insulation over the past decade, yet the energy code is silent onw hether or not it is an acceptable practice. There are concerns about displaced insulation and condensation potential. Both of these issues areaddressed in this proposal.Work sponsored by the Department of Energy and their Building America program definitively show s that their is energy savings associated w ithburying ducts (party or fully) w ithin attic insulation. A recent Home Innovation study measured the summertime delivered air temperature 7 degrees Fcolder w ith R-8 buried ducts than insulated ducts exposed in an attic in a hot humid climate w here no evidence of condensation w as measured(Mallay). Research by Steven Winters and Associates also show s that a buried duct more than compensates for the displaced attic insulation and thereis a net energy savings by burying the ducts partly or fully into the attic insulation (Shapiro).

There have been concerns about burying duct w ork in a hot humid climate (climate zones 1A, 2A, 3A) w here there is an increase in the chances ofcondensation on the vapor retarder around the duct insulation. In order to prevent condensation in the humid climate zones, R-18 duct insulation isrequired rather than R-8 insulated duct. Condensation on the exterior of the duct insulation can be prevented by an R-18 f iberglass duct w ith an exteriorvapor retarder or a duct w ith less (or no) insulation that is encapsulated in a vapor retardant foam that meets the duct requirements of the IRCmechanical section or the IMC.

Bibliography: Compact Buried Ducts in a Hot Humid Climate, Mallay, D. 2016 (page 33)http://apps1.eere.energy.gov/buildings/publications/pdfs/building_america/compact-buried-ducts-hot-humid.pdfMeasure Guideline: Buried and/or Encapsulated Ducts, Shapiro, C, et. al., 2013 (pages 52-56)http://apps1.eere.energy.gov/buildings/publications/pdfs/building_america/measure_guide_buried_encap_ducts.pdf

Buried and Encapsulated Ducts, US Department of Energy, 2013 (page 1)https://w w w 1.eere.energy.gov/buildings/residential/pdfs/ba_in_1.1.3_highperformanceducts_100213.pdf

Cost Impact: Will not increase the cost of constructionThis proposal provides a new option that w ill increase the energy eff iciency of a house w ith ducts in an attic w ithout additional cost in most situations.


RE100-16 : R403.3-DRUMHELLER13073

RE100-16R403.3 (IRC N1103.3), R403.3.6 (New) [IRC N1103.3.6 (New)], R403.3.7 (New) [(IRCN1103.3.7 (New)]Proponent : Craig Drumheller, National Association of Home Builders ([email protected])


R403.3 (N1102.3) Ducts. Ducts and air handlers shall be installed in accordance with Sections R403.3.1 through R403.3.5 R403.3.7.

R403.3.6 (N1103.3.6) Ducts buried within ceiling insulation Where supply and return air ducts are partially or completelyburied in ceiling insulation, such ducts shall comply with all of the following:

1) The supply and return ducts have insulation of an R-value not less than of R-8.

2) At all points along each duct, the sum of the ceiling insulation R-values against and above the top of the duct, andagainst and below the bottom of the duct is not less than R-19, excluding the R-value of the duct insulation.

3) In climate zones 1A, 2A and 3A, the supply ducts are completely buried within ceiling insulation, are insulated to an R-value of not less than R-18 and are in compliance with the vapor retarder requirements of Section 604.11 of theInternational Mechanical Code or Section M1601.4.6 or the International Residential Code, as applicable.

Exception: Sections of the supply duct that are less than 3 feet from the supply outlet shall not be required tocomply with these requirements.

R403.3.7 (N1103.3.7) Ducts located in conditioned space For ducts to be be considered as inside a conditioned space, theducts shall comply with either of the following:

1. The duct system is located completely within the continuous air barrier and within the building thermal envelope.

2. The ducts are buried within ceiling insulation in accordance with Section R403.3.6 and all of the following conditionsexist:

2.1 The air handler is located completely within the continuous air barrier and within the building thermal envelope.

2.2 The duct leakage, as measured either by a rough-in test of the ducts or a post-construction total system leakagetest to outside the building thermal envelope in accordance with Section R403.3.4, is less than or equal to 1.5 cubicfeet per minute (42.5 L/min) per 100 square feet (9.29 m2) of conditioned floor area served by the duct system.

2.3 The ceiling insulation R-value installed against and above the insulated duct is greater than or equal to theproposed ceiling insulation R-value, less the R-value of the insulation on the duct.

Reason: In addition to allow ing ducts to be buried w ithin attic insulation, this proposal sets alternate requirements for ducts to be considered w ithinconditioned space. The DOE Zero Energy Ready Home defines ducts inside conditioned space as, "Duct distribution systems located w ithin the home'sthermal and air barrier boundary or optimized to achieve comparable performance." Item "1)" under R403.3.7 provides for the traditional code definitionof being w ithin conditioned space. How ever, item "2)" in the proposal provides the DOE comparable performance alternative for extremely tight ductsw ith a full complement of insulation, and w ith provision for condensation avoidance for humid climates.

Research has show n that virtually all of the benefit of locating ducts inside conditioned space can be achieved by locating the air handler in conditionedspace and tested, very low leakage insulated ducts in a vented attic buried under ceiling insulation. R403.7 provides for these conditions in that: The airhandler must be located completely w ithin the continuous air barrier and the building thermal envelope; and the ducts must be tested to an extremely lowbut still measurable level of leakage. The sum of the duct R-value and the ceiling insulation immediately above the duct is unchanged from the amount ofprescriptive or proposed ceiling insulation that w ould have otherw ise been installed.

Bibliography: DOE Zero Energy Ready Home National Program Requirements (Rev. 04). May 11, 2015.http://energy.gov/sites/prod/f iles/2015/05/f22/DOE%20Zero%20Energy%20Ready%20Home%20National%20Program%20Requirements%20Rev05%20-%20Final_0.pdf

Cost Impact: Will not increase the cost of constructionThis proposal provides a new option that w ill likely reduce the cost of construction and increase the energy eff iciency of a house w ith ducts in an attic.Burying ducts in insulation and tightly sealing the ducts is a less expensive and more energy eff icient solution than creating a conditioned attic.Additionally, it is often a more practical and homeow ner friendly solution than installing bulkheads in the ceiling to keep ducts in conditioned space.


http://energy.gov/sites/prod/files/2015/05/f22/DOE Zero Energy Ready Home National Program Requirements Rev05 - Final_0.pdf

RE101-16 : R403.3.2-SMITH13281

RE101-16R403.3.2, (IRC N1103.3.2)Proponent : Mark Smith, GreenSeam Industries, representing GreenSeam Industries ([email protected])


R403.3.2 (N1102.3.2) Sealing (Mandatory). Duct construction and installation shall be in accordance with the InternationalMechanical Code or the International Residential Code, as applicable. Ducts, air handlers and filter boxes shall be sealed.Joints Longitudinal and transverse joints, seams and connections of supply and return ducts shall comply be securely fastenedand sealed with either welds, gaskets, mastics (adhesives), mastic-plus-embedded-fabric systems or tapes installed inaccordance with the manufacturer's instructions. International Mechanical Code or International Residential Code, asapplicable.

ExceptionsException:1. Air-impermeable spray foam products shall be permitted to be applied without additional joint seals.2. For ducts having a static pressure classification of less than 2 inches of water column (500 Pa), additional


Reason: The reason for this code change proposal is tw o-fold.

FORMATTING ISSUES:

This proposal clarif ies that the exception should not be exception to the energy code requirements for duct sealing but keeps it in the mechanical codefor residential.

There are inconsistencies in the IECC, IRC and IMC betw een the formatting of the sections on duct sealing and as such, are confusing and diff icult toenforce consistently.

TECHNICAL ISSUES:

The sealing requirements w ithin the IECC (R403.3.2) and the IRC (N1103.3.2) should be clear and easy to understand. This revised text w ill result in adecrease in failed duct leakage tests for energy conservation and energy eff iciency of operation of the HVAC system.

Protection against such leakage is essential to energy eff iciency. When ducts leak because they are not sealed or otherw ise not properly installed,unconditioned air leaks into the return side (negative pressure) and conditioned air leaks out of the supply side (positive pressure) of the HVAC system.The unconditioned air leaking into the HVAC system causes the system to run longer in order to heat or cool the air mass to satisfy the comfortsettings. The conditioned air leaking out of the HVAC system causes the system to run longer because an insuff icient amount of air is delivered to theoccupied zone of the building.

Where higher energy eff iciency is required, particularly for post installation or modif ications of the HVAC system, duct sealing requirements areessential.

The exception to the requirement for sealing ducts in low pressure duct systems to better placed in the residential mechanical code. The IRC alreadysends the code user to Section IRC (M)1601.4.1 for exceptions for duct sealing of joints and seams. The exception to the sealing or closure systemsthat applies to continuously w elded seams and joints, and also for locking-type longitudinal joints and seams in low -pressure duct systems should beretained in the mechanical sections only.

Cost Impact: Will not increase the cost of constructionThe cost impact to this code change proposal is neutral. The requirements for duct sealing, including any permitted exceptions, are already in themechanical section of the IRC and the residential section of the IMC. This proposal directs the user to those code books.


RE102-16 : R403.3.2-SURRENA12470

RE102-16R403.3.2 (IRC N1103.3.2)Proponent : Donald Surrena ([email protected])


R403.3.2 (N1103.3.2) Sealing (Mandatory). Ducts, air handlers and filter boxes shall be sealed. Joints and seams shallcomply with either the International Mechanical Code or International Residential Code, as applicable.

Exceptions:1. Air-impermeable spray foam products shall be permitted to be applied without additional joint seals.2. For ducts having a static pressure classification of less than 2 inches of water column (500 Pa), additional


Reason: These exceptions already exist in the mechanical section of the IRC (1601.4.1) and IMC (603.9). Section R403.3.2 is a pointer and as suchshould not have criteria in it. Why should exceptions to a criteria that is located in another code be placed in the energy code? The most appropriatelocation to address the sealing exceptions for ductw ork is w ithin the mechanical section of the code, w here the w hole criteria and exceptions arecalled out.

Cost Impact: Will not increase the cost of constructionThe code change proposal w ill not change the cost of construction. Code requirements are not proposed to be changed, rather clarif ied as to the intentof the current code.


RE103-16 : R403.3.3-FAY12772

RE103-16R403.3.3 (IRC N1103.3.3), R403.3.4 (IRC N1103.3.4)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


R403.3.3 Duct testing and maximum leakage (Mandatory). DuctsThe ductwork in a building or dwelling unit shall be pressure tested to determine for air leakage. The maximum total air leakageby one rate for ducts in any building or dwelling unit under any compliance path shall not exceed 8 cfm (226.5 L/min) per 100square feet (9.29 m2) of conditioned floor area. Testing shall be conducted at the rough-in stage or post-construction. Total ductleakage shall be measured with a pressure differential of 0.1 inch w.g. (25 Pa) across the entire system, including themanufacturer's air handler enclosure if installed at the time of the following methods:



Exception: A duct air leakage test shall not be required where the ducts and air handlers are locatedentirely within the building thermal envelope.

test. All registers shall be taped or otherwise sealed during the test. Where required by the code official, testing shall beconducted by an approved third party. A written report of the results of the test shall be signed by the party conducting the testand provided to the code official.

R403.3.4 Duct leakage (Prescriptive). The total leakage of the ducts, where measured in accordance with Section R403.3.3,shall be as follows:



Reason: The purpose of this proposal is to reinstate a mandatory duct tightness test requirement, but also to set the backstop at half the level oftightness required under the current prescriptive requirement, and to apply it to all homes. Under the 2012 IECC, all ducts (except those in conditionedspace) w ere required on a mandatory basis to meet the current prescriptive levels. The mandatory nature of the requirement w as removed in 2015,allow ing duct tightness to be fully traded off for other eff iciency measures. We believe some trade-off is acceptable, but that a minimum level of ducttightness is necessary to ensure some reasonable level of duct performance occurs in the home. With extra-leaky ducts, there is no assurance thatconditioned air is provided w here it is needed for adequate comfort. The failure to properly distribute conditioned air is likely to result in excess energyusage in an effort to heat or cool areas (by adjusting the thermostat) w ith an inadequate distribution of conditioned air.

Cost Impact: Will increase the cost of constructionThe addition of a mandatory duct leakage target half as stringent as the prescriptive path requirement should not increase the cost of construction.How ever, in those limited cases w here the ducts are currently not being tested, and w here the ducts and air handler are not located inside the buildingthermal envelope, there w ould be an increased cost of duct testing and the cost of any remedial efforts.


RE104-16 : R403.3.3-MAKELA12645

RE104-16R403.3.3 (IRC N1103.3.3)Proponent : Eric Makela, Cadmus Group, representing RESNET


R403.3.3 (N1103.3.3) Duct testing (Mandatory). Ducts shall be pressure tested in accordance with BRS/RESNET/ICC 380 todetermine air leakage by one of the following methods:





Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: BRS/RESNET/ICC 380-2015 Standard for Testing Airtightness of Building Enclosures, Airtightness of Heating and Cooling AirDistribution Systems, and Airflow of Mechanical Ventilation Systems. Republished January 2016. Addendum A-2015 andAddendum B-2015.

Reason: R403.3.3 Duct testing, currently provides no guidance for testing duct systems to determine if they meet the maximum duct leakage rate. Thecurrent code language sets a duct leakage metric and essentially leaves it up to those that are testing the system to determine how to arrive at theresults. The lack of guidance can lead to inconsistent test results from house to house. This code change proposal solves this problem by requiringtesting to conform to ANSI/RESNET/ICC Standard 380 - Standard for Testing Airtightness of Building Enclosures, Airtightness of Heating and Cooling AirDistribution Systems, and Airf low of Mechanical Ventilation Systems. This standard provides a standardized methodology that is currently in usethroughout the industry. The methodology w ill provide consistent results that can be replicated by testing organizations and enforcement personnel.Why RESNET/ICC Standard 380 Instead of Other Standards. RESNET/ICC Standard 380 has been developed to provide a consensus national standardfor consistent measurement of several air-f low related residential building metrics. It builds off of existing American National Standards to providestandard procedures essential to the evaluation of the energy performance of residential buildings energy. Other standards are in existence but aremore suitable for research and not code enforcement. For example, ASTM Standard E1554-13 describes 4 different test methods (A, B, C, and D) forperforming a duct leakage test. Method A requires multi-point testing of both the enclosure and the distribution system at a range of 5 to 50 Pa in 5 Paincrements using both pressurization AND depressurization of the building enclosure AND distribution system. Method B requires a physical separationof the supply and return distribution systems and that each are tested separately at a 25 Pa pressure difference, w hile measuring the pressuredifference betw een any buffer zones and the outside. This procedure requires several iterations of each test (supply, return, buffer zone). Method Cmeasures distribution system leakage to the outside using a 25 Pa pressure difference across the building enclosure w ith reference to the outsideusing a location sheltered from w ind and sunshine. The distribution system is tested at a 25 Pa pressure difference w ith reference to the outside andthe recording of inside temperature, outside temperature, and barometric pressure at the start and end of each test. This method requires testing underpressurization, w hile Standard 380 allow s pressurization or depressurization (f ield conditions may require depressurization in order to maintain sealson the supply outlets and return inlets). Method D measures total distribution system leakage at a 25 Pa pressure difference w ith reference to theoutside w ithout using a fan (blow er door) to create a 25 Pa pressure difference across the building enclosure to isolate leakage to the outside.Conditions of integrated mechanical ventilation dampers are not mentioned in E1554, w hile Standard 380 provides explicit instructions regardingmechanical ventilation systems integrated w ith the distribution system. ASTM E1554 also has extensive reporting requirements including calibration ofair f low meter, a tabular listing of all air leakage data (air f low s, time, all pressures), and f loor areas and volumes of building (conditioned f loor area,attic, basement, and craw lspace).

Cost Impact: Will not increase the cost of constructionThe protocol for duct testing described in Standard 380 is consistent w ith the testing protocols presented in RESNET certif ications for HERS raters andalso w ith the Duct and Envelope Testing (DET) training sessions that are being deployed in several states to meet the testing needs of the IECC. Thisprotocol is considered industry standard and w ill not increase the time for testing ductw ork, so the cost of testing w ill not increase, but w ill lead to morecompliant duct systems for duct testing professionals that may not be follow ing a protocol. The protocol does not change the target duct air leakagerate so there are no additional costs to seal the duct system to make it code compliant.



RE105-16 : R403.3.3-MOORE11092

RE105-16R403.3.3 (IRC N1103.3.3)Proponent : Mike Moore, Newport representing Broan-NuTone ([email protected])


R403.3.3 (N1103.3.3) Duct testing (Mandatory). Ducts shall be pressure tested to determine air leakage by one of thefollowing methods:




Exception(s):

1. A duct air leakage test shall not be required where the ducts and air handlers are located entirely within the buildingthermal envelope.

2. A duct air leakage test is not required for ducts serving heat or energy recovery ventilators that are not integratedwith ducts serving heating or cooling systems.

A written report of the results of the test shall be signed by the party conducting the test and provided to the code officialcodeofficial.

Reason: This section contains requirements for testing dw elling units' primary heating or cooling system ducts. This proposed change clarif ies thatH/ERV systems that are ducted separately from ducts serving heating or cooling systems are not required to have their ducts tested.

Cost Impact: Will not increase the cost of constructionThis change is a clarif ication only and w ill not increase the cost of construction.


RE106-16 : R403.3.3-SCHWARZ13068

RE106-16R403.3.3 (IRC N1103.3.3), R403.3.4 (IRC N1103.3.4)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R403.3.3 (N1103..3.3) Duct testing (Mandatory). Ducts shall be pressure tested to determine air leakage by one of to thefollowing methods:




outdoors. A written report of the results of the test tests shall be signed by the party conducting the test and provided tothe code official.

The leakage test shall be performed post construction. Leakage to outdoors shall be less than or equal to 4 cubic feet minute(113.3L/min) per 100 square feet (9.29 m2) of conditioned floor area served, (4cfm/100 ft2), when tested at a pressuredifferential of 0.1 inch w.g. (25 Pa) across the entire system, including the manufacturer's air handler enclosure, with a blowerdoor and duct leakage testing device. Registers shall be taped or otherwise sealed during the test.

Exceptions:

1. A duct leakage to outside test shall not be required where the ducts and air handlers are documented, at a roughstage of construction, to be located entirely within the building's air barrier and thermal envelope.

2. Where the HVAC duct work system is serving not more than 1200 square feet of conditioned floor area, theallowable duct leakage to outside target shall be 60 CFM regardless of the calculated 4 cfm/100 ft2 calculations.

3. If a total duct leakage test is performed, a measurement of the 60 cfm or less can be used instead of testing forduct leakage to outside in any software calculations demonstrating compliance with this energy code if that level ofduct leakage demonstrates compliance with the code.

R403.3.4 (N1103.3.4) Duct leakage (Prescriptive). The total leakage of the ducts, where measured in accordance withSection R403.3.3, shall be as follows:



Reason: Currently having both mandatory and prescriptive requirements is confusing. Duct leakage to outside (LTO) testing specif ically addresses theenergy component of duct leakage w hich is the primary intent of the IECC. There are many benefits and reasons w hy one should test total Ductleakage that are in alignment w ith the life safety, durability, comfort intent of the code. How ever, eff iciency of the duct system is only measured by ductleakage to the outside. If one test is all the code can dictate then this is the correct test to choose.

The exception to LTO testing should still stand if all ducts are w ithin the buildings thermal envelope. How ever, w e have added a definition ofhow to determine if the ducts are inside the buildings thermal envelope and air barrier system. This is greatly needed to ensure that there is acommon understanding of w hen the exception can and should be used. For example, ducts w ithin the f loor system of a f loor over a garagew ould now be defined to be w ithin the air barrier of the home and testing for LTO w ould not be required. Currently this distinction is lacking.The 4 cfm/100sqft of f loor area target currently penalizes small units, so w e have introduced a f ix that w as f irst developed by the Energy Starprogram. Currently the duct Total leakage targets at rough-in or f inal is based on amount of conditioned f loor area, regardless of total f loorarea served. In this proposal a 'f loor' has been added to the duct leakage limits. By 'f loor', w e mean a low er limit that doesn't decrease as thespace gets smaller and smaller.

Energy Stars target f loor is 40 CFM. We have used 60 CFM as it is a more reasonable target for small systems in our current state ofinstallation and sealing expertise.

Cost Impact: Will not increase the cost of constructionSw itching from Total duct leakage to Duct leakage to outside only, w ould actually save money as the test w ould not have to be performed on everyhouse. In addition, the test is performed at the same time as the blow er door test so addition visits to the house could be reduced is the testing agencyw as doing a unique visit just for total duct leakage testing services. As the requirement for testing is still being proposed some fee, presumably at leastthe same fee as w as charged for Total Leakage, w ould be charged.


RE107-16R403.3.3 (IRC N1103.3.3), R403.3.4 (IRC N1103.3.4)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R403.3.3 (N1103.3.3) Duct testing (Mandatory). Ducts shall be pressure tested to determine air both total leakage by one of and leakage to the following methods:




outside. A written report of the results of the test tests shall be signed by the party conducting the test and provided to thecode official. 1. Total duct leakage rough-in test or post construction test:The total leakage shall not exceed 4 cfm (113.3 L/min) per 100square feet (9.29 m2) of conditioned floor area where the air handler is installed at the time of the test. Where the air handler isnot installed at the time of the test, the total leakage shall not exceed 3 cfm (85 L/min) per 100 square feet (9.29 m2) ofconditioned floor area. Registers shall be taped or otherwise sealed during the test.

Exceptions:

1. Where the HVAC duct work system serves less than 1200 square feet of conditioned floor area, the allowable totalduct leakage target shall be 60 cfm regardless of the calculated 4 cfm/100 sq ft calculation.

2. Where the total duct leakage measurement is 60 cfm or less, a duct leakage to outside the building thermalenvelope test shall not be required. Such actual leakage measurement can be used as the number entered into anysoftware calculations demonstrating compliance with this code for the performance path duct leakage to outsidepenalty or tradeoff, where the measured number demonstrates compliance with the code in the softwarecalculation.

2. Duct leakage to outside post construction test: Leakage to outside the building thermal envelope shall not exceed 4 cfm(113.3 L/min) per 100 square feet (9.29 m2) of conditioned floor area served when tested at a pressure differential of 0.1 w.g. (25Pa) across the entire system, including the manufacturer's air handler enclosure, with a blower door and duct leakage testingdevice. Registers shall be taped or otherwise sealed during the test.

Exceptions:

1. A duct leakage to outside test shall not be required where the ducts and air handlers are documented, at a rough-instage of construction, to be located entirely within the building's air barrier and thermal envelope.

2. Where the HVAC duct work system serves less than 1200 square feet of conditioned floor area, the allowable ductleakage to outside shall be 60 cfm or less.





Reason:

Currently having both mandatory and prescriptive requirements is confusing. Duct leakage testing is needed and needs to just be required toensure eff iciency, durability, safety, and comfort. All are the intent of the IECC.Both of the current testing paths use the w rong matrix from an energy perspective. In order to ensure the intent of the IECC is maintained itmakes sense to keep the total duct leakage requirement as it deals w ith very important issues that are byproducts of energy eff iciency;


RE107-16 : R403.3.3-SCHWARZ13057

durability, safety, and comfort. Adding a Duct leakage to outside (LTO) testing requirement specif ically addresses the energy component ofduct leakage w hich is also the intent of the IECC. The exception to LTO testing should still stand if all ducts are w ithin the buildings thermal envelope. How ever, w e have added a definition ofhow to determine if the ducts are inside the buildings thermal envelope and air barrier system. This is greatly needed to ensure that there is acommon understanding of w hen the exception can and should be used. For example, ducts w ithin the f loor system of a f loor over a garagew ould now be defined to be w ithin the air barrier of the home and testing for LTO w ould not be required. Currently this distinction is lacking.The 4 cfm/100sqft of f loor area target currently penalizes small units, so w e have introduced a f ix that w as f irst developed by the Energy Starprogram. Currently the duct Total leakage targets at rough-in or f inal is based on amount of conditioned f loor area, regardless of total f loorarea served. In this proposal a 'f loor' has been added to the duct leakage limits. By 'f loor', w e mean a low er limit that doesn't decrease as thespace gets smaller and smaller.

Energy Stars target f loor is 40 CFM. We have used 60 CFM as it is a more reasonable target for small systems in our current state ofinstallation and sealing expertise.

Bibliography: The Energy ConservatoryDuct Leakage to Outside Testing Instructions

Pages 25 through 31

http://energyconservatory.com

Cost Impact: Will increase the cost of constructionCurrently Total duct leakage testing is required. Duct leakage to outside is also required for IECC code sections R405 simulated performance and R406ERI pathw ays. Duct leakage to outside is a tradeable feature and is an input in the modeling softw are used to demonstrate compliance w ith the codew hen using sections R405 and R406. Therefore, the code in essence is currently requiring both tests for these pathw ays through the code. Pricew ould increase for those w ho are using the prescriptive path but should remain the same for those using the simulated performance path or the ERIpath for compliance.

Duct leakage to outside is performed at the same time the blow er door test is performed, as a blow er door and duct leakage testing device must runtogether to for the test, w hich increases the cost effectiveness of this test. Adding this test to the process of compliance should add betw een $50 and$100 to the cost of compliance for those currently using the prescriptive path.


RE108-16 : R403.3.3-SURRENA12553

RE108-16R403.3.3 (IRC N1103.3.3), R403.3.4 (IRC N1103.3.4)Proponent : Donald Surrena ([email protected])


R403.3.3 (N1103.3.3) Duct testing (Mandatory). Ducts shall be pressure tested to determine air leakage by one of thefollowing methods:


2. Postconstruction test: Total Leakage to outdoors shall be less than or equal to 4 cfm (113.3L/min) per 100 squarefeet (9.29 m2 ) of conditioned floor area or total leakage shall be measured with less than or equal to 4 cfm (113.3L/min) per 100 square feet (9.29 m2) of conditionedfloor area when tested at a pressure differential of 0.1 inch w.g.(25 Pa) across the entire system, including the manufacturer's air handler enclosure. Alternatively, a duct leakageto outside test with a pressure differential of 0.1 w.g. (25 Pa) with reference to outside that includes themanufacturer's ait handler enclosure. Registers shall be taped or otherwise sealed during the test.





2. Postconstruction test: Total leakage or leakage to outside shall be less than or equal to 4 cubic feet per minute(113.3 L/min) per 100 square feet (9.29 m2) of conditioned floor area.

Reason: Allow ing the option for measurement of duct leakage to the outside w ill give both HVAC installers and homeow ners an accurate measurement of ductleaks to the exterior of the building. Duct leakage to the outdoors is an accepted duct testing method in the industry and w as allow ed under Section403.2.2 of the 2009 IECC and approved for the 2015 IECC by the committee, but w ithdraw n by the proponent. The proposed leakage rate is set at 4 cfmper 100 square feet of conditioned f loor area w hich consistent w ith the 2015 requirements for total duct leakage. Proposed changes provide clarity asto w hat distribution system eff iciency should be applied to the Standard Reference Design and how the ducts should be modeled in the performancepath.

Cost Impact: Will not increase the cost of construction The code change proposal w ill not increase the cost of construction. Code requirements are not proposed to be changed, rather added options forcompliance w ill have the ability to reduce the cost of construction.


RE109-16 : R403.3.5-COLLINS11458

RE109-16R403.3.5 (IRC N1103.3.5)Proponent : David Collins, representing Sustainability, Energy, High Performance Code Action Committee


R403.3.5 (N1103.3.5) Building cavities (Mandatory). Building framing cavities shall not be used as ducts or plenums.

Exception: Individual wall framing cavities used for transfer air between two spaces on the same level complying with Section602.3 of the International Mechanical Code [IRC Section M1601.1.1.1]

Reason: For the last few editions of the IECC and the IRC, there has been a conflict betw een the energy and duct system provisions regarding the useof stud w all cavities as air plenums. As the IECC requirement w as more stringent, the 'conflict' w as resolved in favor of the energy provisions. TheSEHPCAC discussed the provisions of IRC M1601.1.1 and consider it to be an acceptable approach for return air. Therefore the proposed exceptions toIRC N1103.3.5 and IECC R403.3.5 directs the user to M1601.1.1 for w all framing cavities used to transfer return air betw een tw o spaces on the samelevel.This proposal w as submitted by the ICC Sustainability Energy and High Performance Code Action Committee (SEHPCAC). The SEHPCAC w asestablished by the ICC Board of Directors to pursue opportunities to improve and enhance International Codes w ith regard to sustainability, energy andhigh performance as it relates to the built environment included, but not limited to, how these criteria relate to the International Green Construction Code(IgCC) and the International Energy Conservation Code (IECC). In 2015, the SEHPCAC has held three tw o- or three-day open meetings and 25w orkgroup calls, w hich included members of the SEHPCAC as w ell as any interested parties, to discuss and debate proposed changes and publiccomments. Related documentation and reports are posted on the SEHPCAC w ebsite at: http://w w w .iccsafe.org/cs/SEHPCAC/Pages/default.aspx

Cost Impact: Will not increase the cost of constructionThe code change proposal w ill decrease the cost of construction. Due to current conflict in code, the energy provisions require the use of metalductw ork for all transfer openings, w hile the mechanical provisions allow the use w ithout metal ductw ork. Allow ing the longstanding mechanicalprovisions to be used for transfer air w ill reduce construction costs and not increase energy costs.



RE110-16 : R403.3.6 (NEW)-DRUMHELLER13065

RE110-16R403.3 (IRC N1103.3), R403.3.6 (New) [IRC N1103.3.6) (New)], R403.3.6.1 (New) [IRCN1103.3.6.1(New)]Proponent : Craig Drumheller ([email protected])

2015 International Energy Conservation CodeR403.3 R403.3(N1103.3) Ducts. Ducts and air handlers shall be installed in accordance with Sections R403.3.1 throughR403.3.5 R403.3.6.

R403.3.6 (N1103.3.6) Ducts buried within ceiling insulation Supply and return ducts shall be permitted to be installed partially, orfully buried within ceiling insulation provided they meet the following requirements:

1. Supply and return ducts shall be insulated to a minimum of R-8;2. At all points along the duct, the sum of the ceiling insulation above the top of the duct and below the bottom of the duct shall be aminimum of R-19 excluding the duct R-value;3. In climate zones 1A, 2A, 3A, where supply ducts are fully buried within ceiling insulation, the supply ducts shall be insulated tominimum R-18 and in accordance with the vapor retarder requirements in Chapter 16 (M1601.4.6) of the International ResidentialCode or Chapter 6 (604.11) of the International Mechanical CodeException: Sections of supply ducts less than 3 feet from the supply outlet.


R403.3.6.1(N1103.6.1) Deeply buried duct effective R-value. Sections of ducts installed in accordance with SectionR403.3.6 and directly on or within 5.5 inches of the ceiling board and surrounded with blown attic insulation of R-30 or greaterand the top of the duct is buried a minimum of 3.5 inches below the insulation shall be permitted to claim an effective ductinsulation of R-25 for the deeply buried section of the duct when using a simulated energy performance analysis.

Reason: The proposal, in addition to allow ing ducts to be installed w ithin ceiling insulation, also provides additional effective insulation credit for ductsdeeply buried (more than 3 1/2" under insulation) to claim an effective R-value of R-25. This value is based on peer review ed research conducted bySteven Winters and Associates (Grif f iths) and similar language has been incorporated into California's Title 24 residential energy code (CEC).This w ill be a valuable, energy equivalent, alternative for many builders that have diff iculty designing ducts w ithin the building.

Bibliography: Insulation Buried Attic Ducts: Analysis and Field Evaluation Findings, Grif f iths, D et. al., 2008, (page 1-123)http://w w w .eceee.org/library/conference_proceedings/ACEEE_buildings/2004/Panel_1/p1_11/paper2013 Residential Compliance Manual, California Energy Commission, 2013 (page 4-44)http://w w w .energy.ca.gov/2013publications/CEC-400-2013-001/chapters/04_Building_HVAC_Requirements.pdf

Cost Impact: Will not increase the cost of constructionThis new section creates an option to installing ducts. It is generally less expensive to bury a duct than suspend a duct system installed in an attic. Inaddition, there is an energy eff iciency credit available for ducts that are buried providing further reduction in installed cost of other eff iciencymeasures that may no longer be necessary.


RE111-16 : R403.4-AHERN11472

RE111-16R403.4 (IRC N1103.4)Proponent : Howard Ahern, representing Airex Mfg. ([email protected])


R403.4 (N1103.4) Mechanical system piping insulation (Mandatory). Mechanical system piping capable of carrying fluidsabove 105°F (41°C) or below 55°F (13°C) shall be insulated to a minimum of R-3.

Exception: Piping that conveys fluids that have not been heated or cooled through the use of fossil fuel, electric power orwhere heat gain or loss will not increase energy usage.

Reason: The code requires insulation of all system piping carrying fluids above 105°F and below 55°F. Thischange is needed to clarify this code requirement and exempt insulating piping carrying fluids that have notbeen heated or cooled by fossil fuels or electric power. In addition to exempt piping where heat gain or losswill not increase energy usage such as refrigerant liquid piping.

Cost Impact: Will not increase the cost of constructionThe proposal w ill allow piping insulation to be eliminated in certain cases and that w ill result in a savings of insulation material and installation laborcosts.


RE112-16 : R403.4.1 (NEW)-AHERN13161

RE112-16R403.4.1 (New) [IRC N1103.4.1(New)]Proponent : Howard Ahern, representing Plumberex ([email protected])


R403.4.1 (N1103.4.1) Refrigerant suction piping. Insulation covering refrigerant suction piping that is located outside theconditioned space shall include a Class I or II vapor retarder on the exterior of the insulation.

Reason: Pipe insulation and effective vapor retarders on low-temperature systems are very important and assuch vapor retarders on outdoor Refrigerant suction piping has long been a requirement of the ASHRAE90.1 standard and pipe Insulation manufactures . This code change is needed to ensure sustainablethermal performance by preventing absorption and transference of moisture to outdoor insulation. Just a1% increase in moisture in insulation equates to a 7.5% decrease in thermal conductivity (thermal k).Insulation can air absorbs mostiure from the humidity in the air. *(The vapor retarder is the most important component in an insulation system.) Keeping the pipe insulationdry and ensuring its integrity and preventing leaks which can cause ice to from inside the insulation that candestroy the insulation and can cause a significant increase in load and power usage. This change willmake sure energy saving associated with thermal performance is not lost by degraded ordestroyed insulation from absorption and transference of moisture .

.

Bibliography: 10 tips for Refrigerant pipingASHRAE Journal, March 2004

Daniel R. Kuespert, Ph.D.,

https://www.ashrae.org/.../docLib/.../2004219155519_326.pdf

Cost Impact: Will not increase the cost of constructionVapor barriers are already required by pipe insulation manufacturers (their installation instructions) for outdoor installations. Therefore, the codecurrently requires a vapor barrier because the code already requires adherence to manufacturer's installation instructions. This proposal simply makesit clear to installers (and inspectors) w hat the installation instructions say to do for outdoor insulation on piping.


RE113-16 : R403.5-URBANEK12699

RE113-16R202 (IRC N1101.6) (New), R403.5 (IRC N1103.5), R403.5.1 (IRC N1103.5.1) (New)Proponent : Lauren Urbanek, Natural Resources Defense Council ([email protected])


R202 (N1101.6) DESUPERHEATER/WATER HEATER. A factory-made assembly of elements by which the flows of refrigerantvapor and water are maintained in such heat transfer relationship that the refrigerant vapor is desuperheated and the water isheated. A water circulating pump may be included as part of the assembly.

R202 (N1101.6) GRID-ENABLED WATER HEATER An electric resistance water heater that:1. Has a rated storage tank volume of more than 75 gallons;2. Was manufactured on or after April 16, 2015; 3. Has an energy factor of not less than 1.061 minus the product of 0.00168 times the tank's rate storage volume (ingallons); or an equivalent alternative standard prescribed by the Secretary of Energy and developed pursuant to 42 U.S.C.6295 (e)(5)(E); 4. Is equipped at the point of manufacture with an activation lock; and5. Has a label meeting certain criteria for permanence and states, using text set by the statute, that the water heater isintended only for use as part of an electric thermal storage or demand response program.

Revise as follows:

R403.5 (N1103.5) Service hot water systems. Energy conservation measures for service hot water systems shall be inaccordance with Sections R403.5.1 through R403.5.4 R403.5.5.


R403.5.1 (N1103.5.1) Water heating equipment (Prescriptive). In climate zones 1 through 5 each dwelling unit shall beprovided with one or a combination of the following with the capability to provide hot water to meet the anticipated needs of thedwelling unit:

1. A water heater with desuperheater tested and listed in accordance with AHRI 4702. A heat pump water heater with an energy factor (EF) of 2.0 or greater3. A solar water heating system, which consists of a solar thermal collector combined with a storage tank or any NAECA-compliant water heater, with solar system heating fraction of 0.50 or greater4. An instantaneous water heater5. A storage gas water heater with energy factor (EF) of 0.67 or greater6. A grid-enabled water heater.

Exception: Replacements of existing water heating equipment

Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: AHRI 470-06 Performance Rating of Desuperheater/Water HeatersReason: Residential envelopes have been getting tighter and better over the last few years. As a result, domestic w ater heating energy is emerging asa signif icant end-use from the eff iciency stand-point. There are multiple w ays of improving the eff iciency of generating hot w ater in homes. Previousanalysis performed by DOE analyzed some of the more common w ater heating options for both gas and electric w ater heating. For homes w ith gasw ater heating, DOE analyzed high-eff iciency gas storage w ater heaters and instantaneous w ater heaters; for homes w ith electric w ater heaters, DOEanalyzed heat-pump w ater heaters. Desuperheaters w ere analyzed for all cases.

DOE found that high-eff iciency gas storage w ater heaters not only saved energy over their lifespan, but also cost less to install. Instantaneous w aterheaters w ere cost-effective in the w armer climate zones, but w ere not as cost-effective in the colder climate zones. Heat pump w ater heaters thatreplace electric storage w ater heaters are cost-effective in all climate zones. Desuperheaters are most cost-effective for cooling-dominated climatezones, as they operate only w hen the air conditioners are running. The energy savings from desuperheaters are much higher for w armer climatezones. Given the results of the cost-effectiveness analysis performed by DOE, NRDC recommends that this prescriptive requirement apply to climatezones 1-5.

As part of DOE's appliance and equipment standards initiative, stakeholders expressed to DOE the importance of large-volume electric resistance w aterheaters to electric thermal storage (ETS) programs. Utilities use ETS programs, sometimes also know n as load shifting or demand response programs,to manage peak demand load by limiting the times w hen certain appliances are operated. In certain w ater-heater based ETS programs, a utility typicallycontrols a w ater heater remotely to allow operation only w hen electricity demand is during off-peak hours. During that off-peak operation, the electricityconsumed is stored by the w ater heater as thermal energy for use during peak hours w hen the utility prevents the w ater heater from using electricity.In the Energy Eff iciency Improvement Act (EEIA) of 2015, Congress amended the Energy Policy and Conservation Act (EPCA) to establish a category ofw ater heaters called "grid-enabled w ater heaters" and create an energy conservation standard for that product. The definition of "grid-enabled w aterheaters" in this proposal is consistent w ith the definition adopted into law in EPCA.

Cost Impact: Will not increase the cost of constructionAnalysis by DOE found that high-eff iciency equipment often costs less to install than standard equipment. A new standard for w ater heaters tookeffect in 2015, so by the time the 2018 code is adopted this technology w ill be the industry standard.

Analysis: A review of the standard(s) proposed for inclusion in the code, AHRI 470-06, w ith regard to the ICC criteria for referenced standards(Section 3.6 of CP#28) w ill be posted on the ICC w ebsite on or before April 1, 2016.


RE114-16 : R403.5.6 (NEW)-HOBBS11699

RE114-16R403.5.5 (New) [IRC N1103.5.5 (New)]Proponent : Karen Hobbs, National Resources Defense Council ([email protected]), Ed Osann, National Resources Defense Council([email protected])


R403.5.5 (N1103.5.5) Lavatory faucets (Mandatory). The flow rate of a lavatory faucet installed in a dwelling unit shall notexceed 1.5 gpm (0.11 L/s) at 60 psi (414 kPa).

Reason: Residential lavatory faucets rated at 1.5 gpm or less are commonly available and perform as w ell as those w ith higher f low rates.WaterSense established criteria for residential lavatory faucets and faucet accessories such as aerators in 2007. Based on recent reports byWaterSense partners, over 5,200 models from 134 brands currently meet the WaterSense specif ication, show ing the w idespread availability andcommercial viability of more eff icient lavatory faucets (Source: MaP Testing: http://w w w .map-testing.com/).The Natural Resources Defense Council (NRDC) estimates that signif icant w ater and energy savings could accrue nationw ide if this revised f low ratesfor residential faucets became effective in 2018:

121.9 million gallons of w ater per day in 2030;

2,198 GWh (Gigaw att Hours) of electricity per year in 2030; and

158 therms of natural gas per year in 2030.

The California Energy Commission (CEC) adopted a 1.2 gpm standard in August, 2015. In its review , the CEC analyzed the availability and functionalityof lavatory faucets operating at 1.5 gpm, the same f low rate contained in this proposal. CEC found that "41 percent of lavatory faucets in theCommission's database w ould comply w ith a 1.5 GPM standard. A July, 2016 search of the Commission's database show ed 56 percent of lavatoryfaucets w ould comply w ith the 1.5 GPM standard (California Energy Commission, "Staff Analysis of Lavatory Faucet Appliance Standards," DocketNumber 15-AAER-05, p. 5, July 24, 2015, http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-05/TN205513_20150724T152718_Staff_Analysis_of_Lavatory_Faucet_Appliance_Standards.pdf). Further, "staff did not encounter any issues w ithconsumer acceptance, health and safety, or heat transfer loss from a 1.5 GPM standard and concludes that a 1.5 GPM maximum flow rate is technicallyfeasible" (California Energy Commission, p. 5).

The CEC also found signif icant savings in w ater and energy use as a result of the 1.5 GPM standard, estimating f irst-year annual savings of 3.4 billiongallons of w ater, 89 GWh of electricity, 12 Mthm of natural gas, and consumer savings of 51 million dollars (California Energy Commission, p. 6).

Bibliography: California Energy Commission, "Staff Analysis of Lavatory Faucet Appliance Standards," Docket Number 15-AAER-05, July 24,2015, http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-05/TN205513_20150724T152718_Staff_Analysis_of_Lavatory_Faucet_Appliance_Standards.pdf.

Cost Impact: Will not increase the cost of constructionAs noted above, faucets operating at the f low rates proposed are commonly available and perform as w ell as less eff icient models. EPA WaterSensealso found that, "Most high-eff iciency faucet accessories that restrict f low are no more expensive that their conventional counterparts. How ever,pressure compensating faucet accessories that are designed to provide and maintain a constant f low rate despite f luctuations in w ater pressuretypically cost a few dollars more." http://w w w .epa.gov/WaterSense/faucets.html. Low e's Home Improvement Store features more than 1,759 residentialbathroom faucets that meet the proposed standard of 1.5 gpm from 19 brands, ranging in cost from $15 to $2000 (Source: Low e's Home ImprovementStore w ebsite: http://w w w .low es.com/Bathroom/Bathroom-Faucets/Bathroom-Sink-Faucets/_/N-1z0w z0vZ1z0z4i4/pl#!).The California Energy Commission (CEC) "concluded that there w as no incremental cost betw een a 1.5 GPM faucet and a 2.2 GPM faucet, based onstudies conducted by the investor-ow ned utilities and verif ication through a retail price search show ing no premium for the more eff icient products"(California Energy Commission, p. 6).


RE115-16 : R403.5.6 (NEW)-HOBBS11763

RE115-16R403.5.5 (New) [IRC N1103.5.5 (New)]Proponent : Karen Hobbs, National Resources Defense Council ([email protected]), Ed Osann, National Resources Defense Council([email protected])


R403.5.5 (N1103.5.5) Showerheads. The flow rate of a showerhead shall not exceed 1.8 gpm (0.11 L/s) at 80 psi (552 kPa).

Reason: Show erheads operating at 1.8 gpm at 80 psi are commonly available and perform as w ell as show erheads operating at 2.5 gpm. TheWaterSense specif ication for show erheads w as adopted in 2010, including a maximum flow rate of 2.0 gpm at 80 psi. Based on the most recentreports by WaterSense partners, more than 800 models from 45 brands currently meet the proposed standard, demonstrating the w idespreadavailability and commercial viability of these types of show erheads (Source: MaP Testing: http://w w w .map-testing.com/).In August, 2015, the California Energy Commission (CEC) approved a new standard for show erheads of 1.8 gallons per minute maximum flow ratestarting July 1, 2018. By 2028, the CEC estimates that this standard w ould result in annual savings of 38 billion gallons of w ater; 202 million therms ofnatural gas; 1,322 gigaw att‐hours of electricity; and 702 million dollars of savings for California alone (California Energy Commission, "Staff Analysis ofWater Eff iciency Standards for Show erheads," Docket Number 15-AAER-05, August 7, 2015, http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-05/TN205654_20150807T151426_Staff_Analysis_Of_Water_Eff iciency_Standards_For_Show erheads.pdf).

Bibliography: California Energy Commission, "Staff Analysis of Water Eff iciency Standards for Show erheads," Docket Number 15-AAER-05, August 7,2015, http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-05/TN205654_20150807T151426_Staff_Analysis_Of_Water_Eff iciency_Standards_For_Show erheads.pdf.

Cost Impact: Will not increase the cost of constructionAs noted above, show erheads operating at the f low rate proposed are commonly available and perform as w ell as less eff icient f ixtures. Forshow erheads, more than 800 models from 45 brands currently meet the proposed standard (Source: MaP Testing; http://w w w .maptesting.com/).According to EPA WaterSense, "Show erheads are available at a variety of price points and ranges in cost may be due to a number of factors includingstyle or functional design" (Source: EPA WaterSense: http://w w w .epa.gov/WaterSense/pubs/faq_show erheads.html). Consumer Reports found that,"If you think you have to spend top dollar to get a strong performer, think again. Our top-rated multisetting show erhead costs a quarter of the price ofthe model that f inished second" (Source: Consumer Reports: http://w w w .consumerreports.org/cro/show erheads/buying-guide.htm).The California Energy Commission (CEC), in its staff analysis for its 1.8 gpm standard, found that "the incremental cost for show erheads is zerobecause there is no cost premium for a compliant product (meaning that an eff icient product and an ineff icient product cost the same, all other variablesconstant) (California Energy Commission, p. 15). Further, the CEC found that "consumers should immediately see savings on their utility bill uponinstalling a compliant product" (California Energy Commission, p. 15).


RE116-16R403.6 (IRC N1103.6)Proponent : Mike Moore ([email protected])


R403.6 (N1103.6) Mechanical ventilation (Mandatory). The building shall be provided with mechanical ventilation that meetsthe requirements of the International Residential Code or International Mechanical Code, as applicable, or with other approvedmeans of ventilation. Outdoor air intakes and exhausts shall have automatic or gravity dampers that close when the ventilationsystem is not operating.

Reason: Energy eff icient, tight homes need mechanical ventilation to provide minimum acceptable indoor air quality. This is clearly recognized in theheading of this section, but is not called out explicitly in the text. Currently, the IECC requires all residential dw elling units to have an air tightness of 5ACH50 or low er. Even if the 3-5 ACH50 requirement becomes prescriptive, simply follow ing the IECC's mandatory air sealing checklist w ill easily result in

homes that are 5 ACH50 or tighter (see below for corroborating testimony).1,2,3,4,5,6,7,8,9,10,11 At this tightness, inf iltration can only provide about halfthe ventilation air recommended for residential units (i.e., 0.35 air changes per hour; see chart). Studies have show n natural ventilation via w indowoperation is not able to make up the balance of required outdoor air, because homeow ners do not leave their w indow s open, often due to concerns forsecurity and/or comfort.12,13

This section needs to be clarif ied to leave no doubt that mechanical ventilation is required for any residential dw elling unit follow ing the IECC'smandatory air sealing checklist. The estimated cost of negative health effects associated w ith poor residential indoor air quality exceeds $300 billionannually;14,15,16,17,18 this is too high of a cost to ignore by requiring tight construction w ithout explicitly requiring mechanical ventilation.

Feedback from building off icials and HERS raters has confirmed that follow ing the mandatory IECC air sealing checklist is all that is necessary to achievebuilding tightness below 5 ACH50 (and regularly below 3 ACH50). Follow ing are some examples of this testimony from internet threads, studies, andpersonal communications:

California homes built from 2002-2004: Testing of a random sample of 102 tract homes built in California betw een 2002-2004 (w ell before thedetailed air sealing requirements of the 2009 IECC w ere developed) show ed a median air tightness of 4.8 ACH50.1

Parker, CO: From 2013-2014, only three of the f irst 424 air tightness tests conducted on single family homes built by production builders inParker, CO, failed to achieve 3 ACH50, w ith an average score of 2.3 ACH50. According to the building off icial, this level of tightness w as

achieved by simply follow ing the same air tightness checklist that w as in the 2009 IECC.2

HERS rater in Illinois: "In my experience w ith testing homes in new construction, the 5ACH50 is too easy to achieve. I f ind that the builders don'thave to try very hard to get under 5ACH50. What I f ind most disheartening is that they can pass code (5 ACH50 in Illinois) w ith a blow er doortest and not do any attic air sealing or properly seal rim joists - w hich w ould be my top priorities in most homes. I had a recent test w here I


RE116-16 : R403.6-MOORE11058

w alked aw ay shaking my head. There w ere the usual suspects that I f ind w ith a leaky attic f loor - no top plates sealed, leaky recessed lights,unsealed electrical penetrations, etc. Yet, they easily achieve the 5ACH50."3

Largest HERS Rater in Colorado: "Colorado has had good success in achieving 3 or less ACH50 consistently. We see a consistent average of2.5 ACH50 for single family homes. Follow ing the air tightness table in the code...w ell is the issue to achieve this. How w ell builders follow this

guidance is directly relational to their ability to meet the 3 ACH50 threshold."4

Builder in Illinois: "Our interest in the 1990's and early 2000's w as more driven by reduced homeow ner "cold room" complaints than energycompliance. But w ith that said, w e did, inadvertently, start to build a more energy eff icient home and thereby had a happier customer base andreferral stream... It w as not hard to get to 5 ACH50 at all. But never being required to measure the tightness level of our homes prior to 2010, ...

I w ent back a tested a sampling of homes w e had built in the past 10 years to pleasantly f ind most w ere testing right at or below 5 ACH50."5

Habitat for Humanity aff iliate's experience: "If a habitat for humanity aff iliate can make 5 ACH50 w ith dif ferent volunteers on each house, andthat means retraining them for every build; I think a commercial builder that tells all subs his homes are going to be tested and w ill hit 5 or low er;is easy. This aff iliate builds in a No Energy Code jurisdiction and looks for building tasks their volunteers can do. They turn dow n donations ofsite applied spray on WRB to allow their volunteers to install house w rap."6

HERS rater in Colorado: "Based on the experience of the contractors w e are w orking w ith 5 should be a no brainer and 3 should come w ith afew attention to details. Most of our contractors are consistently at 2 or better and many are at 1."7

HERS rater in Kansas: "I did a brief study for our local HBA as they w ere w orking w ith the code off icials and found most builders w ere at 6ACH before implementation of the 2012 code air sealing requirements. Now most homes build to the code are under f ive w ith the larger homesunder three as a general rule."8

Program manager in Alaska: "The average ACH50 for homes built in Alaska since 2000 (all types) 3.93; Average ACH50 for homes built in

Alaska since 2006 (all types) 3.37; Average ACH50 for homes built in Alaska since 2010 (all types) 2.96."9

Builder from Washington: "Our w orst blow er-door test ever w as our f irst, back in 2005. It came in at just under 2.5 ACH50, and w e didn't even

know w hat a tight house w as back then."10

Connecticut Light and Pow er Study: Blow er door tests on a statistical sample of 69 single family homes built to the 2006 IECC and spreadacross Connecticut found an average air tightness of 5.8 ACH50. These homes w ere built from 2009-2011 and w ere constructed prior to the

state's adoption of the 2009 IECC and its prescriptive air sealing checklist.11 Minimum code compliant homes built since this time are expected tobe tighter.

Bibliography:

1. Offerman, F.J. (2009). Ventilation and indoor air quality in new homes. PIER Collaborative Report. California Energy Commission & CaliforniaEnvironmental Protection Agency Air Resources Board. At the time of construction, air sealing requirements in the CA Building Energy Eff iciencyStandards w ere limited to the follow ing sentence, "Joints and other openings in the building envelope that are potential sources of air leakageshall be caulked, gasketed, w eatherstripped, or otherw ise sealed to limit inf iltration and exfiltration," (CEC 2001 Energy Eff iciency Standards,Section 117). Air sealing of CA residences has been required since 1982. http://w w w .energy.ca.gov/2014publications/CEC-400-2014-024/CEC-400-2014-024-FS.pdf.

2. Email communication w ith Gil Rossmiller, Chief Building Off icial, Parker, CO. Dec 8, 2014.3. Email communication w ith Todd Abercrombie, EverGreen Home Energy Consultants, Inc. Dec 8, 2014.4. Comment from Robby Schw arz, Principal of Energy Logic. Posted on LinkedIn's RESNET.US Group discussion, "How Tough is it to Hit 5 ACH50?"

Dec 10, 2014.5. Email communication w ith Brian Flaherty of Flaherty Buiders. Dec 4, 2014.6. Comment from John Nicholas, HERS Rater w ith The Energy Guy. Posted on LinkedIn's RESNET.US Group discussion, "How Tough is it to Hit 5

ACH50?" Dec 9, 2014.7. Comment from Mark Attard, Sales Consultant at AE Building Systems. Posted on LinkedIn's RESNET.US Group discussion, "How Tough is it to Hit

5 ACH50?" Dec 9, 2014.8. Comment from Bruce Chyka, Ow ner at Performance Plus Homes. Posted on LinkedIn's RESNET.US Group discussion, "How Tough is it to Hit 5

ACH50?" Dec 9, 2014.9. Comment from Nathan Wiltse, Policy Program Manager / Building Economist at Cold Climate Housing Research Center. Posted on LinkedIn's

RESNET.US Group discussion, "How Tough is it to Hit 5 ACH50?" Dec 10, 2014.10. Comment from Ted Clif ton, President of Zero Energy Plans. Posted on LinkedIn's RESNET.US Group discussion, "How Tough is it to Hit 5

ACH50?" Dec 10, 2014.11. KEMA, Cadmus, et al. (2012). Connecticut 2011 Baseline Study of Single-Family Residential New Construction. Available at:

http://energizect.com/sites/default/f iles/ConnecticutNew ResidentialConstructionBaseline-10-1-12_0.pdf. Accessed December 19, 2014.12. Offerman, F.J. (2009). Ventilation and indoor air quality in new homes. PIER Collaborative Report. California Energy Commission & California

Environmental Protection Agency Air Resources Board.13. Klug, V. L., Lobscheid, A. B., & Singer, B. C. (2011). Cooking Appliance Use in California Homes – Data Collected from a Web-Based Survey

LBNL-5028E. Berkeley, CA: Law rence Berkeley National Laboratory.

14. Logue JM, Price PN, Sherman MH, and Singer BC. 2012. A Method to Estimate the Chronic Health Impact ofAir Pollutants in U.S. Residences. Environmental Health Perspectives 120(2): 216-222.

15. Turner WJN, Logue JM, and Wray CP. 2012. Commissioning Residential Ventilation Systems: A Combined Assessment of Energy and Air Quality

Potential Values.

16. Brow n DW. 2008. Economic value of disability-adjusted life years lost to violence: estimates for WHO Member States. Rev. Panam Salud

Publica, 24, 203-209.

17. Lvovsky K, Huges G, Maddison D, Ostro B, and Pearce D. 2000. Environmental costs of fossil fuels: a rapid assessment method w ith

application to six cities. Washington,D.C.: The World Bank Environment Department.

18. Highfill T and Bernstein E. 2014. Using Disability Adjusted Life Years to Value the Treatment of Thirty Chronic Conditions in the U.S. from 1987-

2010. U.S. Department of Commerce Bureau of Economic Analysis WP 2014-9.

Cost Impact: Will not increase the cost of constructionThis is simply a clarif ication of a current requirement, so no additional costs w ill result.


RE117-16R403.6 (IRC N1103.6), R403.6.1 (New) [IRC N1103.6.1 (New)], R403.6.1 (IRC N1103.6.1), TableR403.6.2 [IRC Table N1103.6.2] Proponent : Mike Moore ([email protected])


R403.6 (N1103.6) Mechanical ventilation (Mandatory). The building shall be provided with mechanical ventilation that meetsthe requirements of the International Residential Code or International Mechanical Code, as applicable, or with other approvedmeans of ventilation. Outdoor air intakes and exhausts shall have automatic or gravity dampers that close when the ventilationsystem is not operating.


R403.6.1 (N1103.6.1) Heat or energy recovery ventilation (Prescriptive). Dwelling units shall be provided with a balancedheat or energy recovery ventilation system in climate zones 6, 7 and 8. The system shall have a minimum sensible heatrecovery efficiency of 65% determined in accordance with CSA 439 at 0 °C and at an airflow greater than or equal to thesystem's design whole-house mechanical ventilation airflow.

Revise as follows:

R403.6.1 R403.6.2 (N1103.6.2) Whole-house mechanical ventilation system fan efficacy (Mandatory). MechanicalFans used to provide whole-house mechanical ventilation system fans shall meet the efficacy requirements of Table R403.6.1 R403.6.2.

Exception: Where mechanical ventilation fans are an air handler that is integral to tested and listed HVAC equipment isused to provide whole-house mechanical ventilation, they the air handler shall be powered by an electronicallycommutated motor.

TABLE R403.6.1 R403.6.2 (N1103.6.2)WHOLE HOUSE MECHANICAL VENTILATION SYSTEM FAN EFFICACY


(CFM)

MINIMUM EFFICACY

(CFM/WATT)


(CFM)

HRV or ERV Any 1.2 cf m/watt Any



Bathroom, utility room 10 1.4 cf m/watt < 90



Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: CAN/CSA-C439-09 (R2014) - Standard laboratory methods of test for rating the performance of heat/energy-recoveryventilators.

Reason: DOE analysis has determined that H/ERVs are cost effective in Climate Zones 6-8. This proposal is similar to DOE's proposal in that it w ouldrequrire an H/ERV in these climate zones w hen follow ing the prescriptive path. The main points of divergence betw een this proposal and DOE's are asfollow s:

1. Reduces the proposed SRE from 70 to 65. This increases the number of available products and potentially decreases the cost to buildersw ithout sacrif icing much in terms of eff iciency. Also, it aligns the minimum code-required SRE w ith the minimum SRE permitted by the H/ERVENERGY STAR specif ication used in Canada.

2. Introduces a minimum fan eff icacy level of 1.2 cfm/W for HRVs and ERVs, also aligned w ith the H/ERV ENERGY STAR specif ication used inCanada. Currently, there is no minimum requirement for the fan eff icacy of H/ERVs. Modeling show s that fan energy has a large effect on theoverall performance of an H/ERV, and so a minimum requirement is needed to ensure that consumers are receiving energy-eff icientperformance.

3. Cleanup/clarif ication of other components of the mechanical ventilation section: 1. Clarif ies that the fan eff icacy table only applies to fans used for w hole-house mechanical ventilation.2. Clarif ies the conditions and the test standard w hich are to be used w hen determining the SRE. The test standard and conditions are

aligned w ith those referenced by the H/ERV ENERGY STAR specif ication used in Canada.


RE117-16 : R403.6-MOORE11060

Cost Impact: Will increase the cost of constructionBecause this proposal applies to the prescriptive path only, there is not necessarily an increase in cost. For example, a builder using the ERI pathw aymay f ind that the builder's current package is already achieving a low enough score such that no new or dif ferent systems or costs are necessary orincurred.Note that DOE's analysis show s that H/ERVs are life-cycle cost-effective in Climate Zones 6-8.

Analysis: A review of the standard(s) proposed for inclusion in the code, CAN/CSA-C439-09 (R2014), w ith regard to the ICC criteria for referencedstandards (Section 3.6 of CP#28) w ill be posted on the ICC w ebsite on or before April 1, 2016.


RE118-16R202 (New) [IRC N1101.6 (New)], R403.6 (IRC N1103.6), R403.6.2 (New) [IRC N1103.6.2 (New)],R403.6.2.1 (New) [IRC N1103.6.2.1 (New)], R403.6.2.2 (New) [IRC N1103.6.2.2 (New)], R403.6.2.2.1(New) [IRC N1103.6.2.2.1 (New)], R403.6.2.2.2 (New) [IRC N1103.6.2.2.2 (New)], R403.6.2.2.3(New) [IRC N1103.6.2.2.3 (New)], R403.6.3 (New) [IRC N1103.6.3 (New)], Table R403.6.3 (New) [IRCTable N1103.6.3 (New)], R403.6.4 (New) [IRC N1103.6.4 (New)]Proponent : Joseph Zimmer, Self, representing Joseph Zimmer, Architect ([email protected])

2015 International Energy Conservation CodeR202 (N1101.6) GENERAL DEFINITIONS


HABITABLE SPACE.A space in a building for living, sleeping, eating or cooking. Bathrooms, toilet rooms, closets, halls, storage or utility spacesand similar areas are not considered habitable spaces.

OCCUPIABLE SPACE.Habitable space or a room or enclosed space intended for bathing, grooming, amusement, education or work, and which isequipped with means of egress and light and ventilation facilities meeting the requirements of this code, the InternationalResidential Code or International Building Code as applicable.

VENTILATION FLOOR AREA.Floor area of occupiable spaces including conditioned space, spaces exempt from requirements to be heated or cooled, andunconditioned spaces.

Revise as follows:

R403.6 (N1103.6) Mechanical ventilation (Mandatory). TheWhere the air leakage rate of a building or dwelling unit, as determined from testing in accordance with Section R402.4.1.2, isless than or equal to five air changes per hour (0.08333 air changes per minute), the building or dwelling unit shall be providedwith ventilation that meets the requirements of the International Residential Code or the International Mechanical Code, asapplicable, Section R403.6.2 or with other approvedapproved means of ventilation. Outdoor air intakes and exhausts shall haveautomatic or gravity dampers that close when the ventilation system is not operating.


R403.6.2 (N1103.6.2) Continuous mechanical ventilation. A mechanical exhaust, supply, or combination thereof system shall provide continuous whole building or dwelling unitventilation at a rate not less than determined in accordance with Section R403.6.2.2 when building or dwelling unit is occupied.

Exceptions:

1. Systems that operate intermittently where the system has controls that enable operation for not less than twenty-five percent (25%) of each 4-hour period and the ventilation rate for each twenty-four hour period is not less than ifthe system operated continuously at a rate determined in accordance with Section R403.6.2.2 for the same twenty-four hour period.

2. Systems that operate at a variable rate where the system has controls that enable the ventilation rate for eachtwenty-four hour period to be not less than if the system operated at a constant rate determined in accordance withSection R403.6.2.2 for the same twenty-four hour period.

3. Approved systems having automatic monitoring and controls that enable intermittent or variable rate operation tomaintain set levels of CO2, airborne vapor and other noxious airborne contaminants.

R403.6.2.1 (N1103.6.2.1) Occupant load. The dwelling unit occupant load shall be two occupants for the first bedroom andone occupant for each additional bedroom.

Exception: Where required or approved by the code official, the number of occupants shall be increased or reduced andthe supply air rate in accordance with Section R403.6.2.2.2 increased or reduced accordingly.

R403.6.2.2 (N1103.2.2.2) Ventilation rate. The ventilation rate shall be not less than the maximum rates determined bySections R403.6.2.2.1, R403.6.2.2.2 and R403.6.2.2.3.

R403.6.2.2.1 (N1103.6.2.2.1) Exhaust air rate. The twenty-four hour period exhaust air rate in cfm (L/s) shall be not lessthan 1440 minutes (86,400 seconds) multiplied by the sum of all of the following:

1. 20 cfm (9.44 L/s) for each bath or toilet room.2. 25 cfm (11.8 L/s) for each kitchen.3. The exhaust rates in cfm (L/s) for any other spaces where exhaust air is required or provided.

R403.6.2.2.2 (N1103.6.2.2.2) Outdoor air supply rate. The twenty-four hour period outdoor air supply rate in cfm (L/s) shallbe not less than the product of multiplying 1440 minutes (86,400 seconds) by 15 cfm (7.08 L/s) by the number of occupants asdetermined in accordance with Section R403.6.2.1.

R403.6.2.2.3 (N1103.6.2.2.3) Ventilation volume air changes rate. The twenty-four hour period ventilation volume changes


rate in hours shall be the product of multiplying 24 by VACH as determined by Equation 4-1.

VACH = 0.3 (Vf loor x 8 ft) (Equation 4-1)where:VACH = ventilation volume air changes/hour (ft3/hour)

Vf loor = ventilation floor area (ft2)

For SI: 1 foot = 304.8 mm.

R403.6.3 (N1103.6.3) Ventilation rate reduction for balanced or distributed systems. Where a mechanical ventilationsystem is balanced or distributed, the required minimum ventilation rate determined in accordance with Section R403.6.2 shallbe reduced by multiplying by the applicable factor indicated in Table R403.6.3.

TABLE R403.6.3 (N1103.6.3) VENTILATION RATE REDUCTION FOR BALANCED OR DISTRIBUTED VENTILATION SYSTEMS

Sy stem Ty pe Distributedc (supply to

all habitable spaces and

exhaust from each

space requiring or

providing exhaust)

Not distributedd (spot

to/f rom select spaces)

Balanceda

(supply equals

exhaust rate)

0.67 0.83

Not balancedb

(supply does not equal

exhaust rate)

0.83 1

a. Total mechanical outdoor air supply rate is equal to the total mechanical exhaust rate of bathrooms, toilet rooms, kitchens and otherrooms with exhaust with all supply and exhaust fans operating simultaneously.b. Mechanical outdoor air supply rate is not equal to total mechanical exhaust rate of bathrooms, toilet rooms, kitchens and otherrooms with exhaust with supply and exhaust fans not operating simultaneously.c. Outdoor air supply is provided from an outdoor air source through ductwork or directly to each habitab le space. Exhaust is providedthrough ductwork or directly from each bathroom, toilet room, kitchen and other rooms with exhaust that removes odors, humidity orother noxious airborne contaminants to the outdoors.d. Outdoor air supply is not provided from an outdoor air source through ductwork nor directly to each habitab le space. Exhaust is notprovided through ductwork nor directly from each bathroom, toilet room, kitchen and other rooms with exhaust that removes odors,humidity or other noxious airborne contaminants to the outdoors.

R403.6.4 (N1103.6.4) Mechanical ventilation rate verification. Where required by the code official, the ventilation rate ofthe mechanical ventilation system shall be measured to show conformance with the International Residential Code or theInternational Mechanical Code as applicable, or Section R403.6.2 and, where applicable, Section R403.6.3. The ventilation rateshall be measured using a flow hood, flow grid, or other approved air-flow measuring device. Systems having multiple operatingmodes shall be tested in all modes. An approved agency shall conduct all measurements. A written report of the measurementresults, indicating the verified air-flow rates in all modes of operation, shall be signed by the approved agency conducting themeasurement. Such reports shall be provided to the code official, when requested.

Reason: Ventilation rate w ithin International Residential Code Section M1507.3.3 is not consistent w ith International Mechanical Code Section 403.3 andTable 403.3 for private dw ellings.The IRC is based upon ASHRAE 62.2 - 2010 and the IMC is based upon w hat w as previously in both the IRC Section R303 and IMC Section 403.3.

The ASHRAE 62.2-2010 equation method resulted in often notably low er ventilation rates than if in accordance w ith earlier methods. This low er rate,w hen combined w ith the requirements of IECC Section R402.4.1.2, results in notably low er ventilation rates.

ASHRAE 62.2 - 2013 has also revised the equation such that the amount of ventilation required has risen to levels closer to those that result in methodstill contained in IMC Section 403.3.

This proposal combines the intent of methods of ASHRAE 62.2 w ith those in IMC 403.3 and formerly in IRC R303 and M1507. It appears to be agreed thatthe ventilation rate should have relation to three aspects of a residential building or dw elling unit.

1. Outdoor air supply based upon the number of occupants.

2. Sum of the minimum exhaust air rates from bath/toilet rooms, kitchens and other rooms w ith exhaust.

3. A ventilation volume (breathing zone volume) air exchange rate.

This alternative method requires calculating all three, then using the largest rate. As the number of occupants based upon the number of bedrooms ispresumptuous, including the ventilation volume (breathing zone volume) exchange rate as one of the criteria insures that low ventilation rates basedupon presumed low er than actual occupant load w ill not result in potentially too little ventilation.

Exception number 3 under proposed Section R403.6.2 is also intended to allow automatic CO2, humidity and other airborne contaminant systems to beused to automatically modulate ventilation levels. This provides the potential for already available systems to reduce energy consumption w ithoutinappropriately reducing ventilation rates.


RE118-16 : R403.6-ZIMMER12077

The addition of Section R403.6.3 also encourages distributed and balanced ventilation systems. Distributed systems insure that supply air is delivered toeach habitable space rather than relying on all ventilation (via supply or exhaust) from few spaces. Spaces remote (via horizontal or vertical distance orseries of door or other air f low restrictions) from the spaces w ith exhaust or supply w ill not be provided w ith as much ventilation as those w ith or inclose proximity to those w ith direct outdoor air supply or exhaust. Balanced systems do not rely on or increase the detriment of a leaky buildingenvelope. The requirement for 'balanced and distributed' ventilation systems has long been a part of the IMC Chapter 4. If a system is balanced and/ordistributed, spot ventilation need not remain high enough to insure spaces remote from the spot outdoor air supply or exhaust are adequately ventilated.Limiting the reduction to not more than 0.67 insures that supply air rate is not reduced to less than 10 cfm/occupant and that ventilation volume airchanges rate is not reduced to less than 0.2 air changes per hour.

The addition of Section R403.6.4 permits a code off icial to request an approved agency to verify the ventilation system operates as intended. Withbuilding envelopes, for the purposes of reducing potential for assembly airborne moisture condensation and deterioration, becoming tighter the need forproperly functioning mechanical ventilation systems.

Cost Impact: Will not increase the cost of constructionThis is proposed as an alternative to the current IRC Section M1507.3.3 and IMC Section 403.3 and Table 403.3. Though the author of this proposalhopes that a single method is adopted for all dw elling units (w hether in a multi-family low /mid/high rise or a detached one-tw o family), this methodallow s for transition until the IRC and IMC Sections are review ed and updated in future editions.As space conditioning loads reduce due to higher performing building envelopes and envelopes become tighter, the need for distributed active spaceconditioning systems, particularly w ithin dw elling units, reduces. It w ill become common for the ventilation systems w ithin all building types to becomeindependent from the space conditioning systems. Therefore the ventilation systems may become the only systems incorporating air ducts. The additionof allow ing rate reduction for balanced and distributed systems is consistent w ith this likelihood and is in keeping w ith relying less on leaky buildingenvelopes as a source of ventilation air.

Section R403.6.4, verif ication, is consistent w ith w hat is currently required in commercial provisions Section C408.2.2.1, but is here proposed as onlyrequired if requested by the code off icial. This requirement may, in future editions, become a requirement and then a construction cost increase.


RE119-16 : R403.6.1-MOORE11061

RE119-16R403.6.1 (IRC N1103.6.1)Proponent : Mike Moore ([email protected])


R403.6.1 (N1103.6.1) Whole-house mechanical ventilation system fan efficacy. MechanicalFans used to provide whole-house mechanical ventilation system fans shall meet the efficacy requirements of Table R403.6.1.

Exception: Where mechanical ventilation fans are an air handler that is integral to tested and listed HVAC equipment isused to provide whole-house mechanical ventilation, they the air handler shall be powered by an electronicallycommutated motor. Heat recovery ventilation fans and energy recovery ventilation fans shall be exempt from theprovisions of Section R403.6.1.

Reason: When minimum fan eff icacies w ere introduced in 2012, the reason statement said that H/ERVs w ere intended to be excepted from thissection. How ever, the exception w as not w ritten explicitly w iithin the code language. This proposal clarif ies that H/ERVs should be excepted from theeff icacy requirements that are applicable to exhaust or in-line fans listed in the table. Without this exception, over 95% of H/ERVs cannot comply w iththe 2.8 cfm/W eff icacy listed in the table. The proposal also clarif ies that heating and cooling system air handlers (e.g., those used for furnace, AC, heatpump, etc.) must have an electronically commutated motor if they are also used to provide w hole-house mechanical ventilation.

Cost Impact: Will not increase the cost of constructionThis clarif ies that H/ERVs are excepted from the fan eff icacy requirements, w hich w ill increase available products and reduce tjhe associated costs ofthese systems.


RE120-16 : R403.6.1-MOORE11062

RE120-16R403.6.1(IRC N1103.6.1), Table R403.6.1(IRC Table N1103.6.1)Proponent : Mike Moore ([email protected])



Exception Exceptions: Where mechanical ventilation fans are an air handler that is integral to tested and listed HVACequipment is used to provide whole-house mechanical ventilation, they the air handler shall be powered by anelectronically commutated motor. HRV and ERV fans shall be exempt from the provisions of Section R403.6.1.

TABLE R403.6.1 (N1103.6.1)WHOLE-HOUSE MECHANICAL VENTILATION SYSTEM FAN EFFICACY

SYSTEM TYPEAIR FLOW RATE RANGE

(CFM)

MINIMUM EFFICACY

(CFM/WATT)

Range hood Any 2.8

In-line f an Any 3.8

Other exhaust f an10 to 89 2.8

>= 90 3.5


Reason: This proposal updates the fan eff icacy requirements to the latest version of ENERGY STAR's ventilating products' criteria, simplif ies the faneff icacy table and provides the follow ing needed clarif ications to the requirements:

1. Clarif ies that the fan eff icacy table only applies to fans used for w hole-house mechanical ventilation.2. Clarif ies that H/ERVs are exempt from the fan eff icacy requirements that are applicable to exhaust and in-line fans. Without this exception, over

95% of H/ERVs cannot comply w ith the eff icacies listed in the table.3. Clarif ies that heating and cooling system air handlers (e.g., those used for furnace, AC, heat pump, etc.) must have an electronically

commutated motor if also used to provide w hole-house mechanical ventilation.

Cost Impact: Will not increase the cost of constructionManufacturers have replaced their v3 ENERGY STAR model fans w ith v4 ENERGY STAR compliant fans that meet these higher eff icacy requirements.These higher eff icacies can still be met w ith PSC motors, so there is little to no signif icant cost increase anticipated. Any initial cost increase w ill beoffset w ith annual energy savings of ~$37 (assumptions: 75 cfm, improvement in eff icacy from 1.4 cfm/W to 2.8 cfm/W, 8760 hours/year of operation,$0.12/kWh).


RE121-16 : R403.6.1-MOORE11063

RE121-16R403.6.1 (IRC N1103.6.1), Table R403.6.1 (IRC Table N1103.6.1)Proponent : Mike Moore ([email protected])



Exception Exceptions: Where mechanical ventilation fans are an air handler that is integral to tested and listed HVACequipment is used to provide whole-house mechanical ventilation, they the air handler shall be powered by anelectronically commutated motor.

TABLE R403.6.1 (N1103.6.1)WHOLE-HOUSE MECHANICAL VENTILATION SYSTEM FAN EFFICACY


(CFM)

MINIMUM EFFICACY

(CFM/WATT)


(CFM)

HRV or ERV Any 1.2 cf m/watt Any



Bathroom, utility room 10 1.4 cf m/watt < 90



Reason: This proposal introduces a minimum fan eff icacy for H/ERVs. The eff icacy proposed is the minimum required by the ENERGY STAR H/ERVspecif ication used in Canada. This w ill save homeow ners ~$92/year in fan energy costs versus specifying the w orst performing H/ERVs currentlyavailable on the market (i.e., assuming 0.5 cfm/W fan gets replaced by 1.2 cfm/W fan, 75 cfm, 8760 hours/year of operation, $0.12/kWh). Increasing theeff icacy from 0.5 cfm/W to 1.1 cfm/W is feasible w ithout a signif icant change in motor technology or product cost.

Cost Impact: Will not increase the cost of constructionAt the levels proposed, fan eff icacy is not a major driver of price. Low -cost H/ERVs are available at the eff icacy level proposed.


RE122-16 : R403.6.1-MOZINGO12874

RE122-16R403.6.1 (IRC N1103.6.1)Proponent : Shaunna Mozingo, Colorado Code Consulting-City of Cherry Hills Village, representing Colorado Chapter of ICC EnergyCode Development Committee ([email protected])


R403.6.1 (N1103.6.1) Whole-house mechanical ventilation system fan efficacy. Mechanical ventilation system fans shallmeet the efficacy requirements of Table R403.6.1.

Exceptions:Exception: 1. Where mechanical ventilation fans are integral to tested and listed HVAC equipment, they shall bepowered by an electronically commutated motor.2. Energy RecoveryVentilators or Heat Recovery Ventilators.

Reason: When using ERVs or HRVs to meet the w hole house ventilation requirements it is almost impossible to f ind one that meets the fan eff icacyrequirements in Table R403.6.1. We believe that the benefit gained from using one of these fans for a combinartion ventilation strategy, in lieu of asimple exhaust only or supply only strategy outw eighs the benefit of simply having an eff icient fan and w ould ask that ERVs and HRVs be exemptedfrom this one requirement.

Cost Impact: Will not increase the cost of constructionWe are not removing the requirement for the fans so there is no cost impact.


RE123-16 : R403.6.1-WILLIAMS12223

RE123-16R403.6.1, R403.6.1.2 (New) (IRC:N1103.6.1, N1103.6.1.2 (New))Proponent : Jeremiah Williams ([email protected])


R403.6.1 (N1103.6.1) Whole-house mechanical Heat recovery ventilation system fan efficacy (Prescriptive). MechanicalIn climate zones 6, 7 and 8, buildings shall be provided with a heat recovery or energy recovery ventilation system fans . Thesystem shall meet be balanced to provide a sensible heat recovery efficiency of not less than 70 percent at 0 °C (32 °F) at theefficacy requirements of Table R403.6.1 rated airflow.

Exception: Where mechanical ventilation fans are integral to tested and listed HVAC equipment, they shall be poweredby an electronically commutated motor.


R403.6.1.2 (N1102.6.1.2) Whole-house mechanical ventilation and heat recovery ventilation system fanefficacy. Mechanical and heat recovery ventilation system fans shall comply with the efficacy requirements of Table R403.6.1.

Exception: Mechanical ventilation and heat recovery fans that are integral to tested and listed HVAC equipment shall notbe required to comply with this section provided that such fan motors are electronically commutated.

Reason: The energy used to condition ventilation air is completely lost through exhaust air in exhaust-based ventilation systems. This provisionincreases energy eff iciency of ventilation systems by recovering a portion of energy lost to the exhaust air to condition incoming ventilation air. It alsoprovides for a balanced ventilation system to avoid induced inf iltration/exfiltration and minimize potential dow ndrafting problems. A large majority ofprojects constructed since 2010 in the cold/very cold regions under DOE's Building America program have included heat recovery ventilation.1

Energy Savings: DOE conducted an energy analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.2 Most Heat Recovery Ventilation systems (HRVs) have a sensible heat recoveryeff iciency of 70%-80%.3 The present analysis conservatively assumes a sensible heat recovery eff iciency of 70%. The energy analysis indicates thatHRVs yield annual energy cost savings ranging from 9.4% to 11.2% of IECC-regulated end uses (heating, cooling, lighting and w ater heating), in climatezones 6 through 8.


Bibliography:

1. See Case Studies in the "cold/very cold" regions in the Building America Solution Center at https://basc.pnnl.gov/optimized-climate-solutions/coldvery-cold

2. Taylor, ZT; Mendon, VV; and Fernandez, N. (2015). Methodology for Evaluating Cost-Effectiveness of Residential Energy Code Changes. Pacif ic Northw est National Laboratory for U.S. Department of Energy; Energy Eff iciency & Renew able Energy. PNNL-21294 Rev1. https://w w w .energycodes.gov/development/residential/methodology.

3. See EnergySavers w ebsite http://energy.gov/energysaver/w hole-house-ventilation4. See cost of 70% effective HRV at http://w w w .nrel.gov/ap/retrof its/measures.cfm?gId=10&ctId=236&scId=25225. Russell, Sherman and Rudd. 2007. LBNL 57730 - Review of Residential Ventilation Technologies. HVAC&R Research, Volume 13.6. http://w w w .deckerhomeservices.com/nahb-study.pdf

Cost Impact: Will increase the cost of construction The cost of HRV equipment ranges from $500-1100, depending on the manufacturer and capacity. The present analysis assumes a total measurecost of $1,300 for a single-point HRV system based on the NREL Retrofit Database, inclusive of equipment and installation.4 Russell, Sherman and Ruddfound a similar cost of $1,350 including installation.5 A study conducted by the National Association of Home Builders (NAHB) indicates the life of HRVsto be 20+ years.6 DOE's analysis assumes a 20-year life.

Cost-effectiveness: DOE conducted a cost-effectiveness analysis using the established methodology: https://w w w .energycodes.gov/development/residential/methodology.2 Analysis show s that HRVs are life-cycle cost-effective in climate zones 6through 8. Life-cycle cost savings range from $868 in zone 6 to $4,464 in zone 8. The full analysis is available athttps://w w w .energycodes.gov/sites/default/f iles/documents/iecc2018_R-3_analysis_final.pdf.






http://energy.gov/energysaver/whole-house-ventilation

http://www.nrel.gov/ap/retrofits/measures.cfm?gId=10&ctId=236&scId=2522

http://www.deckerhomeservices.com/nahb-study.pdf



RE124-16 : R403.7-FAY12768

RE124-16R403.7 (IRC N1103.7)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, ICFInternational, representing Energy Efficient Codes Coalition


R403.7 (N1103.7) Equipment sizing and efficiency rating (Mandatory). Heating and cooling equipment shall be sized inaccordance with ACCA Manual S based on building loads calculated in accordance with ACCA Manual J or other approvedheating and cooling calculation methodologies. New or replacement heating and cooling equipment shall have an efficiencyrating equal to or greater than the minimum required by federal law for the geographic location where the equipment isinstalled. New or replacement service water heating equipment shall have an efficiency rating equal to or greater than theminimum required by federal law.

Reason: The purpose of this code proposal is to clarify that service w ater heating equipment, like HVAC equipment, must meet federal minimumeff iciency requirements.

Cost Impact: Will not increase the cost of constructionCode requirements are not proposed to be changed, but simply clarif ied as to the intent of the current code, that the equipment specif ied and installedmeets the eff iciency level established by federal law . Since meeting federal law is required outside of the code, this proposal w ill not affect the cost ofconstruction


RE125-16 : R404.1.1 (NEW)-JOUANEH12704

RE125-16R202 (New) [IRC N1106.1 (New)], R404.1.1 (New) [IRC N1104.1.1 (New)]Proponent : Michael Jouaneh, Lutron, representing Lutron Electronics Co., Inc. ([email protected])


R202 (N1106.1) AUTOMATIC SHUTOFF DEVICE. A device or system capable of automatically turning off electical loadswithout manual intervention.


DIMMER. A control device that is capable of varying the light output of light sources.

Revise as follows:

R404.1 Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lighting fixturesshall be high-efficacy lamps or not less than 75 percent of the permanently installed lighting fixtures shall contain only high-efficacy lamps.

Exception: Low-voltage lighting that is controlled by low-voltage dimmers or automatic shutoff devices.


R404.1.1 (N1104.1.1) Screw-based lighting. Screw-based lamp sockets shall be controlled by a dimmer or an automaticshutoff device. Dimmers and automatic shutoff devices shall not be required for lamp sockets for any of the following:

1. Located in spaces less than 20 square feet.2. Exterior lighting applications.3. Lighting designed for safety or security.4. Located in unconditioned spaces.

Reason: Lifecycle dollar savings for dimmers and occupancy/vacancy sensors even w hen using high-eff icacy (HE) lamps saves even more energythan simply increasing eff icacy to 75 lm/W. Dimmers have a life cycle cost saving of approximately $575 to $1,500. Occupancy sensors have a lifecycle cost savings of $250 to $2,100. See Table 1 under Cost Impact.Why screw -based sockets? Because it is easy to replace a HE screw -based lamp w ith a low -eff icacy (LE) one; having a permanent lighting control inplace w ith guarantee energy savings even if the lamps are replaced.

Forcing homes to put high eff icacy lamps w ill likely result in low -cost low -quality lamps (bulbs) w hich have poor performance, low home ow nersatisfaction, and increasing likelihood of removal after passing inspection. Especially easy to remove are lamps in screw -based sockets.

For details on energy savings from using lighitng controls...See 2014 CEE Residential Lighting Market Characterization study (Appendix A.1 and A.3).

Bibliography: [Residential Lighting Control Market Characterization] [CEE Consortium for Energy Eff icency] [2014] [Pages 61 and 65] [http://library.cee1.org/sites/default/f iles/library/11458/CEE_LightingMarketCharacterization.pdf]

Cost Impact: Will increase the cost of constructionCosts of dimmers and sensors are included in the Life Cycle Savings. See Table 1.Table 1: Life Cycle Savings for Residential Lighting Controls

Dimmer OccupanceSensor

Halogen LED Halogen LED Notes

Product Cost $25.00 $25.00 $20.00 $20.00 Today's average retail cost (doesn't include price reduction over time or home value increase/mortgage impacts)

Annual Savings 42.2 21.2 53.4 12.5 kWh per year per control 2014 CEE Residential Lighting Market Characterization Study

Electricity Rate $0.13 $0.13 $0.13 $0.13 per kWh 2015 Average rate (doesn't include escalation)

Switch Locations 15 15 15 15 per home

Annual Cost Savings $82.29 $41.34 $104.13 $24.38 per home per year Computed

Life Cycle 23 23 23 23 years Equivalent to LED lamp life cycle (conservative estimate as typically the controls last longer than the lamps)

Life Cycle Savings $1,517.67 $575.82 $2,094.99 $260.63 per home Computed (includes cost of product)


RE126-16 : R404.1-HEINMILLER12089

RE126-16R404.1 (IRC N1104.1)Proponent : Glenn Heinmiller, Lam Partners, representing International Association of Lighting Designers ([email protected])


R404.1 Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lighting fixturesshall be high-efficacy lamps or not less than 75 percent of the permanently installed lighting fixtures shall contain only high-efficacy lamps.


Reason: The rationale for this exception has alw ays been unclear, and even more so today w ith the changes in lighting technology. This exception isobsolete and not relevant to the type of lighting technology currently used. Many of the types of LED fixtures used in residential construction that havea transformer could be considered "low -voltage". The exception could also be interpreted to exempt all 12-volt halogen f ixtures, w hich are veryineff icient. This exception is not needed and provides a possible big loophole for someone w ho w anted to "game" the code.

Cost Impact: Will not increase the cost of constructionThere is no correlation betw een the voltage of a lighting f ixture ("low -voltage" or otherw ise) and the cost of a lighting f ixture. Therefore, the removal ofthe exemption w ill have no impact of the cost of construction. The removal of the exemption w ill not require the purchase of light f ixtures that are moreexpensive than w ould be purchased w ith the exemption in place.


RE127-16 : R404.1-COLLINS11478

RE127-16R404.1 (IRC N1104.1)Proponent : David Collins, representing Sustainability, Energy, High Performance Code Action Committee


R404.1 (N1104.1) Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lightingfixtures shall be high-efficacy lamps or not less than 75 90 percent of the permanently installed lighting fixtures shall containonly high-efficacy lamps.


Reason: The lighting market is rapidly moving tow ards high-eff icacy lighting. Raising the minimum lighting eff icacy from 75% to 90% w ill align w ithmarket trends for high-eff icacy performance and greater energy savings. Sw itching to an LED light bulb, for example, can reduce electricityconsumption by more than 80 percent. This code change w ould allow 10% of f ixtures to be non-compliant, thereby accommodating incandesentdecorative lighting f ixtures. The exisiting exception already exempts low -votage lighting.This proposal w as submitted by the ICC Sustainability Energy and High Performance Code Action Committee (SEHPCAC). The SEHPCAC w asestablished by the ICC Board of Directors to pursue opportunities to improve and enhance International Codes w ith regard to sustainability, energy andhigh performance as it relates to the built environment included, but not limited to, how these criteria relate to the International Green Construction Code(IgCC) and the International Energy Conservation Code (IECC). In 2015, the SEHPCAC has held three tw o- or three-day open meetings and 25w orkgroup calls, w hich included members of the SEHPCAC as w ell as any interested parties, to discuss and debate proposed changes and publiccomments. Related documentation and reports are posted on the SEHPCAC w ebsite at: http://w w w .iccsafe.org/cs/SEHPCAC/Pages/default.aspx

Cost Impact: Will not increase the cost of constructionThe price of high-eff icacy lighting is now competitive w ith other lighting as more and more products such as CFLs and LEDs saturate the market. Thelife-cycle costs of LEDs are signif icantly low er than any conventional lamp or light f ixture.



RE128-16 : R404.1-HEINMILLER12090

RE128-16R404.1 (IRC N1104.1)Proponent : Glenn Heinmiller, Lam Partners, representing International Association of Lighting Designers ([email protected])


R404.1 Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lighting fixturesshall be high-efficacy lamps or not less than 75 percent of the permanently installed lighting fixtures shall contain only high-efficacy utilize lamps with an efficacy of not less than 65 lumens-per-watt, or have a total luminaire efficacy of not less than 45lumens-per-watt.


Reason: By 2018, w hen this code goes into effect, many lighting f ixtures installed in new homes may be "integral LED". Integral LED fixtures do nothave a lamp (a separate "light bulb"). The requirement as currently w ritten w ill be confusing and unclear w hen you install f ixtures that don't have alamp. This is already a problem. For a project that uses integral LED fixtures, it's impossible to understand how to comply w ith the requirement or how toenforce it. How do I account for f ixtures that don't have a lamp that I can measure the eff icacy of? We need separate eff icacy requirements for lamps,and for f ixtures that do not have separate lamps.This proposal moves the definition of "high-eff icacy lamp" from the definitions section into the code section itself. A term that is only used in one place inthe code should not be a defined term in the definitions section. This move w ill also make it easier to understand the requirement.

The proposed value of 65 lumens-per-w att for lamps is from the Energy Star Lamp Specif ication 2.0 w hich w ill be effective in January 2017.https://w w w .energystar.gov/products/spec/lamps_specif ication_version_2_0_pd

The proposed value of 45 lumens-per-w att for light f ixtures is from California Title 24 2016, and is also supported by our ow n analysis. We performed asurvey of the types of LED luminaries w hich are commonly used in high-end residential construction. These types of f ixtures have demanding colorquality and glare control requirements that reduce eff icacy.

The eff icacy threshold for f ixtures w ithout separate lamps is low er than that for lamps. This is because f ixture eff icacy measures only the light comingout of the f ixture, not all the light emitted directly from the light source inside. There are many optical ineff iciencies in a light f ixture and much of the lightthat comes directly from the light source is lost inside the f ixture.

Cost Impact: Will not increase the cost of constructionThe effect on cost of construction depends on w hether or not the project uses any f ixtures w ith separate lamps, and w hat the relative cost of thoselamps w ill be in the future. The proposed lamp eff icacy limit w ould prohibit the use of some compact f luorescent lamps, But if the cost of LED lamps isclose to that of CFL lamps by 2018 (as predicted by DOE) then any increase in cost of construction w ill be insignif icant and quickly paid for by energycost savings.


RE129-16 : R404.1-NORMAN11775

RE129-16R404.1, (IRC N1104.1)Proponent : Phillip Norman, representing self ([email protected])


R404.1 (N1104.1) Lighting equipment (Mandatory). Not less than 75 percent of the lamps in permanently installed lightingfixtures shall be high-efficacy lamps or not less than 75 percentof the permanently installed lighting fixtures shall contain onlyhigh-efficacy lamps.


Specific new rules shall support transition toward distributed local electric power generation and shall promote most-efficientappliances. At 2016 revision, special attention shall be given to most-efficient LED downlighting, through exclusive definition asHigh-efficacy. Mention of passing forms of light shall be considered not helpful In the process evolution, less-efficient light formsshall not be regulated and shall only be tolerated as decor. Market forces including evolving absence of Energy Star recognitionshall provide a natural drive toward better luminaire efficiency. Delivery of better luminaires shall be the inspiration for all otherefficiency gains.

Reason: The w ished transition is to most-eff icient LED dow nlighting. In the process, w ords like "lamps in f ixtures", and "high eff icacy lamps" losemeaning, as describing ineff icient point-source lighting. Point-source lighting as decor w ill not be regulated, during the transition.

Cost Impact: Will not increase the cost of constructionLED dow nlights do not require display in invasive holders, alw ays then w ith smaller installed cost.


RE130-16 R405.1 (IRC N1105.1), Table R405.5.2(1) [IRC Table N1105.5.2(1)Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])


R405.1 Scope. This section establishes criteria for compliance using simulated energy performance analysis. Such analysisshall include heating, cooling, lighting, and service water heating energy only.


This section establishes criteria for compliance using simulated energy performance analysis. Such analysis shall include heating,cooling, lighting, and service water heating energy only.

BUILDING COMPONENT STANDARD REFERENCE DESIGN PROPOSED DESIGNLighting Ty pe: in accordance with Section R404.1 As proposed




As proposed





Structural mass







As proposed



















Reason: This proposal updates the scope of the simulated performance alternative, and adds a new row to Table R405.5.2(1).The IECC in Section 404 contains minimum requirements for lighting installed in or at a residential building. With new technologies and controls, there aresignif icant energy savings opportunities that can be easily modeled in a computer simulation.


RE130-16 : R405.1-ROSENSTOCK11967

Other simulation programs already include lighting as part of a simulated performance path for residential buildings.

Cost Impact: Will not increase the cost of constructionThis proposal updates the scope of the building simulation and requires that lighting be part of the simulation. This proposal does not change any of therequirements in the code, and w ill not increase construction costs.


RE131-16 : R405.1-ROSENSTOCK12191

RE131-16R405.1 (IRC N1105.1)Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])


R405.1 (N1105.1) Scope. This section establishes criteria for compliance using simulated energy performance analysis. Suchanalysis shall include heating, cooling and service water heating energy only.

Exception: Energy used to recharge or refuel vehicles that are used for on-road and off-sitetransportation purposes.

Reason: This proposal modif ies the scope to account for off-site transportation. It is very likely that more homes and residential buildings w ill haveinfrastructure to allow occupants to refuel or recharge their light-duty vehicles. With this infrastructure, the homeow ner or tenant can obtain energy fortheir vehicle through the home energy infrastructure. How ever, the energy sent to the vehicles is not used by the building, in either a standardreference design case or a proposed design case.Different vehicles w ill have different sizes of energy storage systems. While some plug-in hybrid vehicles have batteries w ith a capacity of 4-5 kWh,other all-electric vehicles currently on the market have batteries w ith a total capacity of anyw here from 24 to 85 kWh. On an annual basis, the energysent to a vehicle can be signif icant. For example, if a vehicle gets 4 miles per kWh, and the ow ner drives 8,000 miles per year, then the car w illreceive 2,000 kWh through the building infrastructure.

This language is w ritten specif ically for vehicles that can travel on streets and highw ays, aw ay from the building or building site. In other w ords, it issolely for for vehicles that are used for off-site purposes that may obtain their energy through the building energy infrastructure.

How ever, vehicles that are used on site at the building or at the building site for mobility or process purposes (e.g., motorized mobility devices orlaw nmow ers) do not qualify for this exception and could be accounted for like other miscellaneous end-use appliances, if a designer or modelerw anted to (miscellaneous end-uses are not required to be modeled under the current scope).

Cost Impact: Will not increase the cost of constructionThis proposal does not change any of the requirements in Section 405, or the rest of the code, and only addresses how the simulation is to beperformed if such infrastructure is installed at the building. As a result, it w ill not increase the cost of construction.


RE132-16 : R405.1-WILLIAMS12254

RE132-16R405.1 (IRC N1101.5)Proponent : Jeremiah Williams ([email protected])


R405.1 (N1105.1) Scope. This section establishes criteria for compliance using simulated energy performance analysis. Suchanalysis shall include heating, cooling, mechanical ventilation, and service water heating energy only.

Reason: This proposed change corrects a contradiction in the current code. Section R405.1 states that energy analysis for the Simulated PerformanceAlternative compliance path is to include only heating, cooling, and w ater heating energy (i.e., mechanical ventilation is not included). How ever, TableR405.5.2(1) clearly includes specif ications for mechanical ventilation that may differ betw een the proposed design and the standard reference design.This proposal modif ies the Scope section to match the clear direction given in the table.

Energy Savings: The proposal is not expected to produce energy cost savings.


Cost Impact: Will not increase the cost of constructionThis change has no cost impact because it does not change requirements, but rather clarif ies the intent of the current code.



RE133-16 : R405.2-CONNER12790

RE133-16R405.2 (IRC N1105.2)Proponent : Craig Conner, representing self ([email protected])


R405.2 (N1105.2) Mandatory requirements. Compliance with this section requires that the mandatory provisions identified inSection R401.2 be met. All supply and return ducts not completely inside the building thermal envelope shall be insulated to aminimum of R-6.

Reason: Reason: Duct insulation is labeled both "prescriptive" in Section R403.2.1 and "mandatory" in R405.2. It can't be both.

Cost Impact: Will not increase the cost of constructionWill not increase the cost of construction as this proposal does not add any new requirements.


RE134-16R405.2 (IRC N1105.2), Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Craig Drumheller ([email protected])

2015 International Energy Conservation CodeR405.2 Mandatory requirements. Compliance with this section requires that the mandatory provisions identified in SectionR401.2 be met. The proposed total building thermal envelope UA, which is the sum of U-factor times the assembly area. shallbe less than or equal to the UA of the building thermal envelope using the prescriptive U-factors from Table R402.1.4 multipliedby 1.15 in accordance with Equation 4-1. All supply and return ducts not completely inside the building thermal envelopeshallbe insulated to a minimum of R-6.

UAproposed design <=1.15*UAprescriptive reference design Equation 4-1

Revise as follows:






As proposed





Structural mass







Fuel Ty pe/Capacity : Same as proposed design

Ef f iciencies:Electric:air source heat pump comply ing with prev ailing f ederal

minimum standards.

Nonelectric f urnaces: natural gas f urnace comply ing with prev ailingf ederal minimum standards

Nonelectric boilers: natural gas boiler comply ing with prev ailing f ederalminimum ef f iciencies

As proposed

As proposed

As proposed

As proposed

As proposed

Cooling sy stemsd, f

As proposed Capacity : sized in accordance with Section R403.7.Fuel Ty pe/Capacity : Same as proposed design

Ef f iciency : comply ing with prev ailing f ederal minimum standards.

As proposed

As proposed

As proposed

Serv ice water heatingd, e, f , g

As proposed Use: same as proposed design

Fuel Ty pe: Same as proposed design

Ef f iciency : comply ing with prev ailing f ederal minimum standards

Use: gal/day = 30 + 10 x Nbr

Tank temperature: 120ºF


As proposed

As Proposed

Same as standard ref erence












As proposed





Structural mass


For masonry basement walls, as proposed, but with insulation required As proposed


by Table R402.1.4 located on the interior side of the wallsFor other walls, f or ceilings, f loors, and interior walls, wood f rame

construction As proposed




As proposed



















Reason: This proposal includes energy neutral trade-offs for equipment eff iciency, but also includes a reasonable thermal envelope through a theaddition of a UA backstop.The new ERI compliance path in the 2015 IECC reintroduced equipment eff iciencies as part of energy neutral trade-offs and also included a newconcept of requiring a reasonable minimum thermal envelope in a performance-type analysis. This proposal takes this "reasonable envelope" conceptand applies it to the Simulated Performance Alternative (Section 405). How ever, rather than pointing to the prescriptive tables in a previous version ofthe IECC as is done in the ERI, the thermal backstop becomes a percent UA trade-off. The UA calculation w ill be performed internally w ith thecompliance softw are. It is an easy calculation as all the necessary information is already entered (component area and U-factors/R-values). This shouldnot be problematic as it is already done for w indow s.

Energy neutral equipment trade-offs had been in the IECC residential section for years. Equipment trade-offs are included in every other energycode/standard and above code program in the United States:

IECC CommercialASHRAE 90.1IgCCNational Green Building StandardLEED CommercialLEED for HomesEnergy StarRESNET

The fear that has been spread w ith bringing back equipment trade-offs is that the envelope w ill be substandard. The proposed UA trade-off of 15%considered a reasonable envelope backstop and is on par w ith the assumption that the 2012 IECC is roughly 15% more eff icient than the 2009 IECC.

This proposal serves to retain energy-neutral equipment trade-off provisions from the 2006 IECC for heating and cooling systems and service w aterheating. By retaining these, builders have an opportunity to optimize a code-compliant house design by using energy-eff icient equipment. Quite often,the use of this high-eff iciency equipment provides a more cost-effective solution to achieve code compliance. Eliminating this ability discourages theconcept of the "house as a system" approach, w hich is a cornerstone of building science.

This energy neutral trade-off is important for some industries such as log home manufacturers w ho may no longer be able to cost effectively constructto current and projected higher envelope requirements. The combination of increases in envelope thermal requirements, building tightness and ducttightness combined w ith the elimination of energy neutral trade-offs pose a serious threat to the viability of the log home industry. There are practicallimitations to the thickness of log home w alls. Increasing requirements for the log diameter has a exponential increase in the cost of the logs, making logw alls w ith a U- factor of 0.082 or low er prohibitively expensive.



RE134-16 : R405.2-DRUMHELLER12964

Use of the energy neutral equipment tradeoff is an option that w ill likely reduce the cost of construction. In many cases the cost to increase equipmenteff iciency is less than many of the prescriptive requirements in the code.


RE135-16 : R405.2-FAY12800

RE135-16R405.2 (IRC N1105,2)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


R405.2 (N1105.2) Mandatory requirements. Compliance with this section requires that compliance with all of the following:

1. The mandatory provisions identified in Section R401.2 shall be met.

2. All building thermal envelope components such as insulation and fenestration shall comply with the building thermalenvelope requirements specified under Section R406.2.

3. All supply and return ducts not completely inside the building thermal envelope building thermal envelope shall beinsulated to a minimum of R-6.

Computer software used to determine compliance in accordance with Section R405 shall incorporate the requirements of thissection such that compliance will only be achieved when these requirements are met. The compliance reports required inSection 405.4.2 shall have a list of the requirements of this section for each building component and an indication of eachbuilding component's compliance with those requirements.

Reason: The primary purpose of this proposed code change is to establish reasonable mandatory requirements for a minimum thermal envelope underthe performance compliance path in section R405. In order to maintain consistency w ith the same requirements applicable under the ERI compliancepath in section R406, the proposal simply references the requirements in section R406. This proposal also establishes requirements for computersoftw are consistent w ith these mandatory requirements to improve code compliance. The fact that the mandatory provisions in the ERI compliance path already establish minimum thermal envelope requirements underscores the need forsuch a backstop w hen allow ing various energy eff iciency measures to be traded through any type of performance-based analysis. The reasons forestablishing minimum thermal envelope requirements for the ERI are w ell-established: A w ell-built thermal envelope provides long-term energy savingsand improved comfort for occupants over the lifetime of the home, and upgrades to the thermal envelope are easiest to incorporate (and most cost-effective) at construction. This is consistent w ith the intent of the IECC set forth in Section R101.3. Specif ically, the IECC is intended to "regulate thedesign and construction of buildings for the effective use and conservation of energy over the useful life of each building."

This logic applies to the standard performance compliance path under section R405 as w ell. Regardless of the compliance option selected by the codeuser, the IECC should require a reasonable level of performance by the home's thermal envelope. As a result, this proposal w ould apply the samemandatory requirements, including envelope requirements, to section R405 compliance as currently apply to section R406 compliance. This proposalw ill serve to better align the requirements under the tw o performance compliance paths in sections R405 and R406.

Cost Impact: Will increase the cost of constructionThe additional requirements proposed for Section R405.2 w ill serve only as a backstop to ensure that a minimum reasonable thermal envelope w ill beprovided. Because this backstop is incorporated into an optional compliance path (the performance path), this proposal does not require the builder toincur additional cost. Instead, the builder has the potential to incur additional cost only if the builder selects this compliance path. Moreover, since thissection does not require overall eff iciency beyond that w hich is required in Section R405, w hen the code user selects this compliance path, the costimpact (if any) is entirely dependent on design choices made by the builder. For example, if a building complying via section R405 already meets orexceeds the prescriptive thermal envelope requirements of the IECC, as is likely in many cases, then the thermal envelope backstop proposed forSection R405.2 w ill have no cost impact. By contrast, if the building w ould have been constructed w ith a w eaker thermal envelope than the proposedbackstop, and the difference w ould have been offset by improvements to other components of the building in order to achieve the requisite simulatedperformance, the cost impact w ill depend on w hether the upgrades to non-envelope components cost more or less than the envelope improvementsw ould have cost.We note that the prescriptive improvements made to the IECC prescriptive path during the past few years (w hich are the basis for the backstop) havealready been demonstrated to be cost-effective to the consumer – irrespective of other trade-offs that may take place. For example, the U.S. DOE foundthat over a 30-year useful lifetime, an ow ner of a home built to the prescriptive and mandatory measures of the 2015 IECC (as compared to the 2009IECC) w ould save betw een $4,418 and $24,003 in energy costs, depending on climate zone. See V. Mendon, et. al., Pacif ic Northw est NationalLaboratory, National Cost-Effectiveness of the Residential Provisions of the 2015 IECC, at iv (June 2015),https://w w w .energycodes.gov/sites/default/f iles/documents/2015IECC_CE_Residential.pdf. These f igures include the expected costs of the upgradesover the 2009 IECC. DOE also found that homeow ners w ould achieve a positive cash f low w ithin the f irst tw o years in every climate zone. Id. at v. Theanalysis show s an estimated simple payback period that ranges betw een 2.2 years and 8.1 years, again depending on climate zone. Id.

Thus, if the improved thermal envelope requirement drives builders to incorporate improvements to the thermal envelope consistent w ith the prescriptiverequirements of the IECC, these improvements have already been show n to be cost-effective to the homeow ner by U.S. DOE.


RE136-16R405.3 (IRC N1105.4)Proponent : Keith Dennis, representing NRECA ([email protected])


R405.3 (N1105.4) Performance-based compliance. Compliance based on simulated energy performance requires that aproposed residence (proposed design)be shown to have an annual energy cost that is less than or equal to the annual energycost of the standard reference design.Energy prices shall be taken from a source approvedby the code official,such as theDepartment of Energy, Energy Information Administration's State Energy Price and Expenditure Report. Code officialsshall bepermitted to require time-of-use pricing in energy cost calculations.

Exception:The energy use based on site or source energy expressed in Btu or Btu per square foot of conditioned floorareashall be permitted to be substituted for the energy cost. The Where used in a simulation, the source energymultiplier for electricity shall be 3.16 2.04. The source energy multiplier for fuels other than electricity shall be 1.1.

Reason: The "source" energy metrics used to gauge the relative performance of electric generation are based on EIA methodologies establishedbefore reducing carbon dioxide emissions w as a policy objective and before renew able energy generation w as a signif icant contribution to the electricgrid. As NREL notes in their report of source energy metrics, the source-site ratios are "based on the assumption that most of the electricity w asproduced from thermal electric pow er plants. The result tells nothing of the fuel types consumed or the emissions from the electricity production." [i] Thismeans that before even taking into account the eff iciency of an electric appliance itself, the electricity from the grid used to pow er the device hasalready been determined by energy eff iciency tools and policies to be less than a third as eff icient as on-site fossil fuel, no matter how it w asgenerated.

Figure 1: 2011 Electricity Flow (in Quadrillion Btu)[ii]The EIA Electricity Flow chart (Figure 1), upon w hich the source energy metric is based, is designed to illustrate the relative contribution of energy byfuel type into the electrical system. In order to illustrate the relative portion of non-fossil fuel in the grid, an artif icial conversion for electricity generatedby non-fossil fuels is used. For renew able energy, for example, a fossil fuel heat rate above the average for natural gas plants is used, see Figure 2.How ever, those artif icial conversions are not appropriate for the purposes of illustrating relative resource eff iciency or environmental performance ofthe various non-fossil fuels. The conversions are not based on any practical science and are contradictory to the policy objectives that the sourceenergy metric is designed to address.

Figure 2: Approximate Heat Rates for Electricity New Generation Calculations Used by EIA in Energy FlowUsing these heat rates to calculate source-site energy ratios makes the ratio insensitive to changes in the grid mix. In fact, adding renew able energy


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generation to the electric grid w ould have the same effect on the ratio as adding the average fossil fuel generation using EIA's methodology. Addingnuclear generation w ould actually increase the source-site ratio for electricity, w hich w ould signal consumers to invest in more on-site fossil fuelcombustion as the grid low ers emissions. This is the opposite of policy objectives, is not understood by even the most informed consumers,[iii] and islikely an unintended f law in the methodology of the ratio that is just coming to light as use of the metric increases.

A Pow er Systems Engineering study replicating the EIA's methodology under various hypothetical scenarios demonstrates the f law s in the w ay thesource energy metric is currently calculated. The analysis show s that a sw itch of all coal-f ired pow er in the country to renew able energy w ould resultin a source-site ratio of 2.99 (see Figure 3). Under this scenario, despite using non-emitting sources to provide 71% of the grid's pow er, consumersw ould still be incentivized three to one to have gas end uses rather than electric.

Figure 3: Source-Site Ratios Using EPA/DOE Methodology[iv]Of critical concern, and driving the need to f ix this metric, is that a myriad of energy policy tools are built on this f law ed source energy metric. Outputfrom these policy tools, for example, forms the basis for deciding w hether homeow ners and businesses should be provided or denied incentives basedon the energy performance of their homes and buildings. These consumers are given inaccurate signals from the government and are improperlyincentivized due to the f law s in this metric. This is in contrast to the intent of the tools w hich is to help consumers to be better informed marketparticipants. [v]

As the nation moves forw ard in an effort to curb carbon dioxide emissions, use of this metric in policy runs counter to those goals – especially in thecontext of EPA's Clean Pow er Plan (CPP). Under the CPP or other policies that cap emissions in the electric sector, there could be a signif icant andunintended incentive to sw itch consumers from a more environmentally beneficial electric system to one that burns fossil fuel on-site. The emissionsfrom this one-site combustion w ould not be subject to the electric sector cap, so the sw itch from electricity to on-site gas w ould simply shift theemissions to sectors not covered under the cap. Use of source metrics in combination w ith other climate policies could thus lead to compliance of theelectric-sector GHG rules w hile simultaneously signif icantly increasing GHG emissions of the country overall.

With new grid-connected combined cycle natural gas plants that are over 60% eff icient, increasing new renew able electric generation on the grid, andlarge contributions of non-fossil hydro and nuclear pow er, it is inaccurate and inappropriate to characterize electricity as one-third as eff icient as site-delivered fossil fuel. Since these metrics are subject to debate in many forums, from code hearings and appliance standards proceedings to legislation,there is an opportunity for utilities, environmental advocates, and policy makers to w ork to f ix this issue. One proposal w ould be to simply replace thecurrent "source" energy metric w ith a "fossil source" energy metric using data from the same EIA chart. A sample calculation w ith this simple change tothe calculation used to derive the current metric is presented in Figure 10.[vi] This solution w ould better align the source energy metric w ith its intent ofreducing primary fossil fuel use and its associated emissions. In addition to correcting the f law ed treatment of renew able resources, NRDC's commentsto DOE also include a proposal to use a "marginal source" value to better ref lect the types of generation that pow er new appliances.[vii]

Figure 4: Sample Calculation of a "Fossil Source" Energy MetricFor more context, please the peer-review ed article published in the Electricity Journal entitled "Beneficial Electrif ication: Electricity as the End-UseOption." http://dx.doi.org/10.1016/j.tej.2015.09.019

[i] M. Deru, P. Torcellini. 2007 Source Energy and Emission Factors for Energy Use in Buildings. NREL. p.4.

[ii] EIA. Electricity Flow 2011. Modif ied for better display.

[iii] For example, BSD-151: Understanding Primary/Source and Site Energy, by Kohta Ueno and John Straube, states: "Of course, over time, the fractionof renew able energy is expected to increase, making the grid 'greener.' With the retirement of old coal, the addition of w ind, high eff iciency gas,biomass, tidal, or even nuclear, the carbon intensity of producing electricity w ill drop, and the source-site ratio w ill drop." The idea put forth by theseexperts is not accurate as increasing use of these fuels w ill not signif icantly affect the source-site ratio. This highlights the level of confusion aroundthe source metric and the technical details of how it is calculated.

[iv]David Williams. 2014. Source-Site Ratios. Pow er Systems Engineering.

http://w w w .nreca.coop/w p-content/uploads/2015/04/sourcesite_ratios_final_022015.pdf

[v] Keith Dennis. The Electricity Journal. 2006. The Compatibility of Economic Theory and Proactive Energy Eff iciency Policy. Vol.19. Issue 7. P. 61.

[vi] This w ould replace the use of the 40.04 quads listed as "energy consumed to generate electricity" w ith the 26.48 quads of fossil fuel used togenerate electricity in source calculations. The result w ould indicate the grid fossil source portion of the electric grid is currently approximately 50%, orthe "fossil source-site" ratio is approximately 2.

[vii] NRDC Comments to DOE Docket: EERE-2014–BT–STD–0031. July 2015 at 7.

Bibliography: Dennis, K., Environmentally Beneficial Electrif ication: Electricity as the End-Use Option. Electr. J. (2015),http://dx.doi.org/10.1016/j.tej.2015.09.019



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RE136-16 : R405.3-DENNIS12746

This proposal only changes how an energy simulation is to be performed, and does not have any impact on the costof construction.


RE137-16 : R405.3-FAY12799

RE137-16R405.3 (IRC N1105.3)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, representingEnergy Efficient Codes Coalition


R405.3 (N1105.3) Performance-based compliance. Compliance based on simulated energy performance requires that aproposed residence (proposed design)be shown to have an annual energy cost over a 30 year useful life of the building, on apresent value basis, that is less than or equal to the annual energy cost over a 30 year useful life of the building, on a presentvalue basis, of the standard reference design.Improvements in energy efficiency in the proposed design over the StandardReference Design shall revert to the Standard Reference Design at the end of the useful life of the improvement. Energy prices,energy price escalation rates, discount rates, the useful life of specific building features and components including installedenergy efficiency measures in the building and all other necessary assumptions for the analysis shall be taken from a sourceor sources approvedby the code official,such as the Department of Energy, Energy Information Administration's State EnergyPrice and Expenditure Report . Code officialsshall be permitted to require time-of-use pricing in energy cost calculations.


Reason: The purpose of this code change is to improve the eff iciency of buildings and the accuracy of the performance path compliance option underSection R405. The proposal modif ies the current methodology by replacing annual energy cost analysis w ith a present value analysis of energy cost(by ref lecting the useful life of various energy eff iciency measures) over the useful life of the building. The U.S. Department of Energy applies a similarmethodology in its cost-effectiveness calculations, and updates it regularly through a public process. Seehttps://w w w .energycodes.gov/development/residential/methodology.The current section R405.3 calculates the annual energy cost in the f irst year of a proposed new home and compares it against a baseline StandardReference Design home to determine compliance. A major problem w ith this approach is the fact that it only compares energy cost in the f irst year anddoes not factor in how long each measure being considered w ill provide benefits (frequently measures that save energy longer also cost more). Thehome is designed to last for many years and over such period energy costs w ill change and various components of the home and energy eff iciencymeasures w ill be required to be replaced due to shorter useful lives. This fact is recognized in the Intent of the IECC, Section R101.3 w hich is directedat regulating "the design and construction of buildings for the effective use and conservation of energy over the useful life of each building."

The f law in the current approach is illustrated w ell by the comparison of tw o eff iciency measures – lighting versus thermal envelope. The componentsof the thermal envelope are expected to last far longer than the lighting, providing benefits over a much longer period, but the current compliancemethodology, if applied to these tw o options, w ould measure the benefits of each option as if they had the same useful life – specif ically, over only thefirst year of operation. This could result in the replacement of a longer-life measure w ith a much shorter-life measure and a loss of energy eff iciency.

A more sophisticated analysis w ould account for these changes over time. The proposed change is intended to require this more sophisticatedanalysis. Specif ically, the proposed changes require:

the use of a 30-year useful building life;energy costs to be escalated over time;incorporation of the useful life of each feature of the building constituting an energy eff iciency improvement over the standard referencedesign, by requiring that the analysis assume that the feature revert to the standard reference design at the end of its useful life;the use of the present value of energy costs for comparison purposes; and the assumptions for the analysis be derived from a sourceapproved by the code off icial.

If this proposal is approved, the US Department of Energy could adapt its cost-effectiveness methodology or another party could develop a similarprocess for determining reasonable inputs, and this improved methodology could be easily incorporated into REScheck and other compliance softw are.

Cost Impact: Will increase the cost of constructionBuilders are not required to use this compliance option, so the requirement w ill not necessarily increase the cost of the construction in many cases. How ever, for builders w ho elect to use Section R405 to comply, designers are granted the ability to select the most cost-effective eff iciency featuresfor the home to be built. The initial construction cost for features that have a longer useful life may be higher than those w ith a shorter useful life – if so,this analysis could result in a higher construction cost. How ever, over the life cycle of the home the combined construction and operational costs w ill bereduced as investments in eff iciency features w ill realize savings over a longer period of time.


RE138-16R405.3 (IRC N1105.3)Proponent : Charles Foster, representing self ([email protected])



Exception:The energy Energy use based on source site energy expressed in Btu or Btu per square foot of conditionedfloor areashall be permitted to be substituted for the energy cost. The source energy multiplier for electricity shall be3.16. The source energy multiplier for fuels other than electricity shall be 1.1.

Reason: General:While there are several jurisdictions in the United States that use source energy as the basis of their energy codes, the overw helming majority useeither site energy or cost. This exception (in R405.3) w as originally offered to accommodate those few jurisdictions that have chosen to use sourceenergy.

One of the challenges for use of source energy in codes is that the relationship betw een site and "source energy" consumption is not w ell defined. Forinstance, the 3.16 value currently in the code assumes that electricity produced from w ind, solar, hydro and other forms of renew able energy isequivalent to the consumption of fossil fuels. The same assumption holds for electricity derived from nuclear energy. Thus, from a source energyperspective an unbiased observer w ould be relatively indifferent betw een choosing electricity from 100% renew able sources (w ind or hydro forinstance) and diesel, fuel oil, or gas. This outcome does not seem helpful.

In addition, the mix of sources for the production of electricity (w ind, solar, hydro, nuclear, coal, oil, gas, geothermal, etc.) changes – and w ill continueto change dramatically going into the future w ith the proliferation of additional renew able energy resources (especially w ind) into the national mix. Evenif the 3.16 source energy multiplier w as a good number w hen it w as originally adopted (something this proposal disagrees w ith as argued above), it issurely not still valid.

Finally, it is important to recognize that the impact of the IECC w ill be realized in the future – codes considered today w ill have marketplace impactsstarting in 2018 so looking at electric source energy multipliers today (2015) that are based on data from 2014 (or earlier) for use in 2018 (or later) islikely to convey to users inaccurate pictures of actual resource impacts.

Specific:Part I: Net Zero Energy Buildings

The use of site energy is more appropriate for buildings that are producing or storing energy on-site. In the future,many buildings w ill be producingenergy and storing energy, along w ith consuming energy. Building systems may be consuming energy that w as produced from an off-site energy gridand/or produced from an on-site energy production system and/or delivered from an off-site energy storage system (e.g., a grid battery or EVbattery)and/or delivered from an on-site energy storage system, (e.g., and battery or fuel storage tank or thermal energy storage system). At the sametime, the building may be producing energy that is used by building equipment, sent to an on-site energy storage system, or exported to another building(or buildings) or to the energy grid.

Below is w hat ASHRAE w rote to DOE on the subject of "zero energy" buildings:

"Recommendation II: Define "Net Zero Energy Building" Using Site Energy, With Sub-classif ications Based on Source Estimates, Building Energy Cost,and Building Emissions.

In line w ith ASHRAE 's Vision 2020 document, the Society encourages the Department to adopt the follow ing definition of net zero energy building:

'A net zero energy building (NZEB) is a building that produces as much energy as it uses w hen measured at the site. On an annual basis, itproduces or consumes as much energy from renew able sources as it uses w hile maintaining an acceptable level of service and functionality.NZEBs can exchange energy w ith the pow er grid or other building energy supply grids or systems (e.g., natural gas, propane, etc.) as long asthe net energy balance is zero on an annual basis'

In the same letter, ASHRAE also said:

"How ever, the Society believes that the multiple and varying w eighting factors and algorithms required for estimating source energy conversionsare often inconsistent and ultimately cloud and complicate understanding. Since source energy conversion factors vary w idely from place toplace and across time, the use of f ixed national average conversion factors could lead to inconsistent estimates of consumption."

"Thus, in this case the best method for determining if a building is a NZEB is to look at the energy crossing the boundary at the site of the building;hence "site" energy is the best choice to use."

Part II: Reasons for the Use of Site Energy

Site energy w as part of the exception for many years until it w as recently removed. There are many reasons to allow site energy to be used instead ofenergy costs:

Site energy is an actual metric that can be measured and verif ied by code off icials, w hile source energy is an estimate.Site energy information is credible, as it is show n on customers' energy bills on a monthly basis and used in other consensus-based codedocuments, such as ASHRAE 90.1, ASHRAE 90.2, and ICC-700 use site energy metrics for eff iciency requirements.DOE uses site energy information in many of its energy eff iciency and energy consumption publications, such as the Residential EnergyConsumption Survey.DOE uses site energy for its appliance energy eff iciency standards program and the FTC uses site energy on the yellow EnergyGuide labelsfound on consumer appliances. EPA uses site energy to determine if an appliance or home qualif ies for the Energy Star program.Site energy is reliable, since it can be measured by utilities, consumers, and independent 3rd In terms of energy eff iciency upgrades,consumers rely on site energy information (amount used by older appliance or equipment compared to new appliance or equipment) to helpthem make energy eff iciency decisions.Site energy is replicable, as the units of measurement (kWh, therms, gallons, Btu's) can be used throughout the United States and are familiar toconsumers on their monthly energy bills. Source energy is not replicable, as different estimates must be used for dif ferent energy sources, anddifferent entities can make different assumptions about upstream production and delivery of dif ferent energy sources.Site energy is transparent and easy to understand. It can be based on meter readings or DOE test procedures or FTC EnergyGuide labels orEnergy Star labels. It is the metric that allow s people to easily compare energy eff iciency options in the marketplace. It is the metric that allow speople to make good economic choices w hen faced w ith competitive alternatives.


RE138-16 : R405.3-FOSTER12560

Part III: New source energy estimates penalize the use of renew ables

In a November 2015 published by the American Gas Association paper entitled "Dispatching Direct Use", available at https://w w w.aga.org/sites/default/f iles/dispatching_direct_use__achieving_greenhouse_gas_reductions_the_use_of_natural_, there is a table of revised "full fuelcycle" (source) estimates that claim to show that using renew able energy is w orse that using fossil fuels:

These "estimates" have signif icant policy impacts. It could lead building ow ners and policy makers to go aw ay from using renew able forms of energy.In programs such as Energy Star Portfolio Manager and certain green building programs that use source energy estimates, buildings w ill get much worse scores by using renew able forms of energy (either on-site or from the grid).

Summary: To improve the performance path, and to not penalize renew ables, the performance path should be based on site energy.

Cost Impact: Will not increase the cost of constructionThis proposal does not directly or indirectly impact the specif ic requirements for constructing new homes and, as such, w ould not impact the cost ofconstruction.


RE139-16R405.3 (IRC N1105.3), Table R405.3(1) (New) [IRC Table N1105.3(1) (New)], Table R405.3(2)(New) [IRC Table N1105.3(2) (New)], Table R405.3(3) (New) [IRC Table N1105.3(3) (New)], TableR405.3(4) (New) [IRC Table N1105.3(4) (New)], Table R405.3(5) (New) [IRC Table N1105.3(5) (New)],Table R405.3(6) (New) [IRC Table N1105.3(6) (New)], Table R405.3(7) (New) [IRC Table N1105.3(7)(New)]Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])



Exception:The energy use based on site energy or source energy expressed in Btu or Btu per square foot ofconditioned floor areashall be permitted to be substituted for the energy cost. The source energy multiplier estimatemultipliers for electricity energy sources shall be 3.16 taken from Tables R405.3(1) through R405.3(7). The sourceenergy multiplier for fuels other than electricity shall be 1.1.

TABLE R405.3 [N1105.3(1)]ELECTRICITY SOURCE ENERGY ESTIMATES BY NERC REGION

NERC Region

Acrony m

NERC Region Name Ov erall "source" ration of upstream heat input to end use

(based on eGRID 2012)

"Source" Ratio in 2030 Under Clean Power Plan

(or State RPS)

ASCC Alaska Sy stems Coordinating

Council

2.54 2.54

FRCC Florida Reliability Coordinating

Council

2.48 1.86

HICC Hawaiian Islands Coordinating

Council

2.76 1.66

MRO Midwest Reliability

Organization

2.23 1.51

NPCC Northeast Power Coordinating

Council

1.60 1.08

RFC Reliability First Corporation 2.15 1.46

SERC SERC Reliability Corporation 2.18 1.48

SPP Southwest Power Pool 2.76 1.88

TRE Texas Regional Entity 2.20 1.47

WECC Western Electricity

Coordinating Council

1.67 1.14

TABLE R405.3(2) [N1105.3(2)]

ELECTRICITY SOURCE ENERGY ESTIMATES BY eGRIDSUBREGION

eGRID Subregion eGRID Subregion Ov erall "source" ratio of upstream heat input to end use (based "Source" ratio in 2030 under Clean Power Plan (or


Acrony m Name on eGRID 2012) State RPS)

AKGD ASCC Alaska Grid 2.99 2.99

AKMS ASCC Miscellaneous 1.02 1.02

ERCT ERCOT All 2.20 1.47

FRCC FRCC All 2.48 1.86

HIMS HICC Miscellaneous 2.38 1.43

HIOA HICC Oahu 2.91 1.74

MROE MRO East 2.51 1.71

MROW MRO West 2.20 1.50

NYLI NPCC Long Island 3.02 2.42

NYCW NPCC NYC /

Westchester

2.01 1.61

NEWE NPCC New England 1.71 1.16

NYUP NPCC Upstate NY 0.99 0.80

RFCE RFC East 1.69 1.15

RFCM RFC Michigan 2.75 1.68

RFCW RFC West 2.27 1.54

SRMW SERC Midwest 2.69 1.83

SRMV SERC Mississippi

Valley

2.29 1.56

SRSO SERC South 2.26 1.54

SRTV SERC Tennessee

Valley

2.25 1.53

SRVC SERC Virginia /

Carolina

1.75 1.19

SPNO SPP North 2.69 1.83

SPSO SPP South 2.79 1.90

CAMX WECC Calif ornia 1.68 1.46

NWPP WECC Northwest 1.14 0.77

RMPA WECC Rockies 2.89 1.96

AZNM WECC Southwest 2.09 1.42

TABLE R405.3(3) [N1105.3(4)]


ELECTRICITY SOURCE ENERGY ESTIMATES BY STATES

State Abbrev iation Ov erall "source" ratio of upstream heat input to end use (based on eGRID 2012) "Source" Ratio in 2030 under Clean Power Plan (or State RPS)

AK 2.54 2.54

AL 1.96 1.32

AR 2.27 1.50

AZ 1.88 1.16

CA 1.59 1.38

CO 2.70 1.67

CT 1.31 1.22

DC 3.09 2.47

DE 2.99 2.27

FL 2.50 1.88

GA 2.07 1.36

HI 2.76 1.66

IA 2.14 1.24

ID 0.37 0.34

IL 1.60 0.93

IN 3.10 1.89

KS 2.47 1.41

KY 3.28 2.00

LA 2.53 1.79

MA 2.20 1.80

MD 2.05 1.29

ME 2.00 1.78

MI 2.32 1.41

MN 1.99 1.15

MO 2.72 1.72

MS 2.30 1.89

MT 1.92 1.02

NC 1.90 1.29


ND 2.64 1.45

NE 2.45 1.47

NH 1.44 1.11

NJ 1.27 0.98

NM 2.91 1.86

NV 2.09 1.63

NY 1.48 1.18

OH 2.72 1.74

OK 2.61 1.78

OR 0.64 0.51

PA 1.92 1.28

RI 2.49 2.09

SC 1.44 0.94

SD 0.85 0.53

TN 1.82 1.11

TX 2.32 1.55

UT 2.91 1.92

VA 1.74 1.18

VT 0.26 0.06

WA 0.27 0.17

WI 2.28 1.44

WV 3.04 1.79

WY 3.12 1.75

TABLE R405.3(4) [N1105.3(4)] NATURAL GAS SOURCE ENERGY ESTIMATES BY EIA PIPELINE REGION

EIA Natural Gas Pipeline Region Ov erall "source" ratio of upstream losses to end use (based on EIA and DOE reports)

Western 1.42

Central 1.53

Southwest 1.15

Midwest 1.42


Southeast 1.25

Northeast 1.38

Alaska 1.15

TABLE R405.3(5) [N1105.3(5)] PROPANE GAS SOURCE ENERGY ESTIMATES BY EIA NATURAL GAS PIPELINES

EIA Natural Gas Pipeline Region Ov erall "source" ratio of upstream losses to end use (based on EIA and DOE reports)

Western 1.50

Central 1.61

Southwest 1.21

Midwest 1.50

Southeast 1.32

Northeast 1.46

Alaska 1.21

TABLE R405.3(6) [N1105.3(6)] PIPELINE GAS SOURCE ENERGY ESTIMATES BY TYPE OF CRUDE OIL

Crude Oil Source Ov erall "'source" ratio of upstream losses to end use (based on EIA and DOE reports)

Domestic 1.54

Imported 1.77

TABLE R405.3(7) [N1105.3(7)] SOURCE ENERGY ESTIMATES BY TYPE OF CRUDE OIL

Crude Oil Source Ov erall "source" ratio of upstream losses to end use (based on EIA and DOE reports)

Domestic 1.19

Imported 1.37

Reason: This proposal w ill make the provision more f lexible for building designers, building ow ners, and code off icials. By allow ing the use of siteenergy, w hich w as allow ed in previous versions of the IECC, the performance path can be based on real measured data. By updating source energyestimates, there w ill be more information provided to code off icials and building ow ners. Issue 1: Net Zero Energy Buildings

Allow ing the use of site energy is more appropriate for buildings that are producing or storing energy on-site. In the future, many buildings w ill beproducing energy and storing energy, along w ith consuming energy. Building systems may be consuming energy that w as produced from an off-siteenergy grid and/or produced from an on-site energy production system and/or delivered from an off-site energy storage system (e.g., a grid battery orEV battery) and/or delivered from an on-site energy storage system, (e.g., and battery or fuel storage tank or thermal energy storage system). At thesame time, the building may be producing energy that is used by building equipment, sent to an on-site energy storage system, or exported to anotherbuilding (or buildings) or to the energy grid.

Below is w hat ASHRAE w rote to DOE on the subject of "zero energy" buildings:

"Recommendation II: Define "Net Zero Energy Building" Using Site Energy, With Sub-classif ications Based on Source Estimates, Building Energy Cost,and Building Emissions

In line w ith ASHRAE's Vision 2020 document, the Society encourages the Department to adopt the follow ing definition of net zero energy building:

'A net zero energy building (NZEB) is a building that produces as much energy as it uses w hen measured at the site. On an annual basis, it producesor consumes as much energy from renew able sources as it uses w hile maintaining an acceptable level of service and functionality. NZEBs canexchange energy w ith the pow er grid or other building energy supply grids or systems (e.g., natural gas, propane, etc.) as long as the net energybalance is zero on an annual basis'

In the same letter, ASHRAE also said:

"How ever, the Society believes that the multiple and varying w eighting factors and algorithms required for estimating source energy conversions areoften inconsistent and ultimately cloud and complicate understanding. Since source energy conversion factors vary w idely from place to place andacross time, the use of f ixed national average conversion factors could lead to inconsistent estimates of consumption."

"Thus, in this case the best method for determining if a building is a NZEB is to look at the energy crossing the boundary at the site of the building; hence


"site" energy is the best choice to use."

Issue 2: Reasons for Re-Allow ing the Use of Site Energy

Site energy w as part of the exception for many years until it w as recently removed. There are many reasons to allow site energy to be used instead ofenergy costs:

Site energy is an actual metric that can be measured and verif ied by code off icials, w hile source energy is an estimate.

Site energy information is credible, as it is show n on customers' energy bills on a monthly basis and used in other consensus-based codedocuments, such as ASHRAE 90.1, ASHRAE 90.2, and ICC-700 use site energy metrics for eff iciency requirements.

DOE uses site energy information in many of its energy eff iciency and energy consumption publications, such as the Residential EnergyConsumption Survey. DOE uses site energy for its appliance energy eff iciency standards program and the FTC uses site energy on the yellowEnergyGuide labels found on consumer appliances. EPA uses site energy to determine if an appliance or home qualif ies for the Energy Starprogram.

Site energy is reliable, since it can be measured by utilities, consumers, and independent 3rd parties. In terms of energy eff iciency upgrades,consumers rely on site energy information (amount used by older appliance or equipment compared to new appliance or equipment) to helpthem make energy eff iciency decisions.

Site energy is replicable, as the units of measurement (kWh, therms, gallons, Btu's) can be used throughout the United States and are familiar toconsumers on their monthly energy bills. Source energy is not replicable, as different estimates must be used for dif ferent energy sources,and different entities can make different assumptions about upstream production and delivery of dif ferent energy sources.

Site energy is transparent and easy to understand. It can be based on meter readings or DOE test procedures or FTC EnergyGuide labels orEnergy Star labels. It is the metric that allow s people to easily compare energy eff iciency options in the marketplace. It is the metric that allow speople to make good economic choices w hen faced w ith competitive alternatives.

Issue 3: Revision of Source Energy Estimates

There are many w ays to estimate upstream energy losses. The energy production industry is very dynamic and subject to signif icant changes. In theUnited States in 2015, there w as a record amounts of natural gas produced from hydraulic fracturing production techniques. In 2015, there w as arecord amount of oil produced and imported from oil sands production. In 2015, there w as a record amount of electricity produced from renew ableforms of energy and a record amount of electricity produced by combined-cycle natural gas turbines.

The values that are currently show n should be deleted and not used for the follow ing reasons:

The values show n are not consistent w ith values show n in other published documents.

Many documents and articles have been published over the past several years w ith source energy estimates. Among them are:

National Renew able Energy Laboratory NREL/TP-550-38617 "Source Energy and Emission Factors for Energy Use in Buildings" (June 2007)

American Gas Association EA 2009-3 "A Comparison of Energy Use, Operating Costs, and Carbon Dioxide Emissions of Home Appliances" (October2009)

Environmental Protection Agency "Energy Star Performance Ratings Methodology for Incorporating Source Energy Use" (August 2009)

National Renew able Energy Laboratory NREL/TP-550-47246 "Building America Research Benchmark Definition" (January 2010)

International Code Council "International Green Construction Code" (March 2012)

U.S. Department of Energy Residential Dishw asher Energy Eff iciency Technical Support Document, May 2012:

http://w w w 1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/67

U.S. Department of Energy Residential Furnace Fan Technical Support Document, June 2012:

http://w w w 1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/41

International Code Council "International Green Construction Code (May 2015)

The current values in the IECC do not match and cannot be substantiated w ith any of these published documents.

Different fossil fuels have different upstream source estimates.

In the current IECC, all fossil fuels are assumed to have the same multiplier. In other documents, there is a large and statistically signif icant variation inthe upstream estimates that w ill have a signif icant impact on energy performance results. As one example, for fuel oil and propane, EPA's PortfolioManager uses a factor of 1.01 for both, w hile NREL used estimated values of 1.158 and 1.151, w hile IGCC 2015 uses 1.19 for fuel oil and 1.15 forpropane.

The use of 3.16 for electricity is overstated for many parts of the United States and does not account for signif icant regional dif ferences or theincrease in the use of renew able pow er generation and combined cycle gas turbines.


http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/67

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/41

In other publications and w eb sites, the estimates for electricity are show n on a national basis, a regional basis, or a state by state basis. This is due tothe variety of electric generation techniques w hich have upstream energy losses that can vary by orders of magnitude based on local conditions,regional conditions, physical location, season, month, w eek, or day, as w ell as hourly f luctuations in the amount of sunlight or w ind speed.

In the IGCC Table 602.1.2.1, there are 26 values show n for electricity, based on the pow er pool sub-region in w hich a building is located. The values inthe IGCC table (w hich are based on outdated 2010 electric generation data and incorrect "marginal" estimates) range from 1.90 to 3.82.

The revisions to the values are based on reports published by the US Energy Information Administration, the US Department of Energy, the USEnvironmental Protection Agency, national labs, and other public sources of information. It is a technical fact that there are signif icant regionaldifferences in terms of upstream estimates for electricity as w ell as fossil fuels. The new estimates provide more granular estimates.

For electricity, the spreadsheets w ith updated estimates are below :


For example, in terms of natural gas production, the US EIA w rote in 2011 (Today in Energy, 11/23/2011) "Over one-third of natural gas producedin North Dakota is flared or otherwise not marketed". In March 2013, the North Dakota Department of Mineral Resources w rote "Additions togathering and processing capacity are keeping up w ith the percentage of gas f lared holding at 29%. The historical high w as 36% in September 2011." For end-users receiving gas from this production, it is impossible to have a "source" factor any less than 1/0.71 = 1.408

As the MIT report show s, the central and southw est portions of the US are the key producers of natural gas and export gas to other regions. As theDOE/NETL report show s, there are signif icant dif ferences in energy losses depending on the type of gas production, and how far the gas has to travelvia pipeline (and the use of natural gas compressors).

According to the EPA report on Greenhouse Gas Emissions published in August 2015 (page 8, Figure 2), there are signif icant regional dif ferences inGHG emissions (and energy losses). Figure 2 on page 8 show s that for dif ferent regions in Canada, the CO2e emissions vary by as much as 30%depending on the region w here the natural gas w as produced.


RE139-16 : R405.3-ROSENSTOCK11888

Issue 4: Impact of Federal Policies

As a result of federal policies (such as the EPA Mercury and Air Toxics Rule of 2012 and the August 2015 Clean Pow er Plan), there w ill be a signif icantchange in how electricity w ill be produced in the US. The EPA rules are already having a signif icant impact. States must f ile implementation plans w ithEPA starting by September 2016, for implementation and meeting the EPA requirements by 2030. The tables for electricity source estimates (except forpow er control areas) show values based on eGRID 2012 as w ell as projected values for 2030, based on the EPA Clean Pow er Plan or stateRenew able Portfolio Standards.

Since buildings w ill be built in the future and consume electricity in the future, and not the past, the 2030 values provide realistic estimates that can beused by code off icials that are interested in future estimated impacts.

Summary: This proposal provides more f lexibility and makes key updates based on recent reports and policies, rather than use static and outdatedvalues

Bibliography: ND Department of Mineral Resources 03/15/13 Report https://w w w .dmr.nd.gov/oilgas/directorscut/directorscut-2013-03-15.pdf MIT "The Future of Natural Gas" : http://mitei.mit.edu/system/files/NaturalGas_Report.pdf

WRI Working Paper April 2013 "Clearing the Air: Reducing GHG Emissions from U.S. Natural Gas Systems" http://w w w .w ri.org/publication/clearing-air

Congressional Research Service March 2014 "Canadian Oil Sands: Life Cycle Assessments of Greenhouse Gas Emissions"https://w w w .fas.org/sgp/crs/misc/R42537.pdf

DOE / NETL-2011/1522, "Life Cycle Greenhouse Gas Inventory of Natural Gas Extraction, Delivery, and Electricity Production" (October 24, 2011) http://w w w .netl.doe.gov/energy-analyses/pubs/NG-GHG-LCI.pdf

EPA eGRID 2012 October 2015 http://w w w .epa.gov/energy/egrid

EPA Portfolio Manger Technical Reference "Greenhouse Gas Emissions", August 2015, https://portfoliomanager.energystar.gov/pdf/reference/Emissions.pdf

CERA "Oil Sands, Greenhouse Gases, and US Oil Supply Getting the Numbers Right—2012 Update" http://w w w .api.org/~/media/Files/%20Oil-and-Natural-Gas/Oil_Sands/CERA_Oil_Sands_GHGs_US_Oil_Supply.pdf

Carnegie Endow ment for International Peace, "The Carbon Content of Global Oils", December 2012, http://carnegieendow ment.org/f iles/global_oils.pdf

Cost Impact: Will not increase the cost of constructionThis proposal only changes how the energy simulation in R405.3 is to be performed, and does not have any impact on the cost of construction.


https://www.dmr.nd.gov/oilgas/directorscut/directorscut-2013-03-15.pdf

http://mitei.mit.edu/system/files/NaturalGas_Report.pdf

RE140-16 : R405.3-ROSENSTOCK12237

RE140-16R405.3 (IRC N1105.3)Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])


R405.3 (N1105.3) Performance-based compliance. Compliance based on simulated energy performance requires that aproposed residence (proposed design)be shown to have an annual energy cost that is less than or equal to the annual energycost of the standard reference design.Energy prices shall be taken from a source approvedby the code official,such as theDepartment of Energy, Energy Information Administration's State Energy Data System Prices and Expenditures reportsStateEnergy Price and Expenditure Report . Code officialsshall be permitted to require time-of-use pricing in energy costcalculations.


Reason: This proposal updates the reference to the DOE Energy Information Administration's current publications of state energy pricing data. On itsState Energy Data System (SEDS) w eb site, EIA publishes reports on recent year energy prices by state, as w ell as time series reports on energyprices (e.g., 1970 to 2013). Modifying this reference w ill allow code off icials to use a recent year of data for energy prices or a time series of prices (e.g., 3 recent years) to get alonger average energy price.

Bibliography: EIA State Energy Data System, "State Energy Price and Expenditure Estimates 1970 Through 2013" http://w w w .eia.gov/state/seds/archive/seper2013.pdf Web site links:

http://w w w .eia.gov/state/seds/

http://w w w .eia.gov/state/seds/archive/#2013

Cost Impact: Will not increase the cost of constructionThis is merely an update to an information source that can be used as part of a performance-based compliance path, does not change anyrequirements in the code, and does not affect the cost of construction.


RE141-16 : R405.4 (NEW)-CONNER12831

RE141-16R405.4 (New) [IRC N1105.4 (New)]Proponent : Craig Conner, representing self ([email protected])


R405.4 (N1105.4) On-site renewable energy. On-site renewable energy shall be considered as a reduction in the energy useof the building.

Reason: This treats renew able energy generated at residences as an energy savings for that residence. Renew able energy use reduces theconsumption of non-renew able fossile fuels. The code should recognize and credit residences that choose to reduce energy use by using on-siterenew ables.

Cost Impact: Will not increase the cost of constructionThe addition of renew able energy sources to a building site is a choice, not a requirement. Certainly, such additions w ill increase the cost ofconstruction of the building but because such additions are not required, there is not an increase in the cost of construction to comply w ith the minimumrequirements of the code. This new section provides an energy credit (for having installed a renew able energy system) against the energy cost of theproposed building as compared to the standard reference design building (that did not have a renew able energy system installed). This could possiblydecrease the cost of construction of the building as there is "free energy" available to compensate for less needed stringency in the building's energydesign to meet the annual energy cost of the standard reference design.


RE142-16 : R405.4.2-SCHWARZ12448

RE142-16IECC: R405.4.2.Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R405.4.2 (N1105.4.2) Compliance report. Compliance software tools shall generate a report that documents that theproposed design complies with Section R405.3. A compliance report on the proposed design shall be submitted with theapplication for the building permit. Upon completion of the building, a compliance report based on the as-built condition of thebuilding shall be submitted to the code official before a certificate of occupancy is issued. Batch sampling of buildings todetermine energy code compliance for all buildings in the batch shall only be prohibited allowed for stacked multifamily units.

Compliance reports shall include information in accordance with Sections R405.4.2.1 and R405.4.2.2. Where the proposeddesign of a building could be built on different sites where the cardinal orientation of the building on each site is different,compliance of the proposed design for the purposes of the application for the building permit shall be based on the worst-caseorientation, worst-case configuration, worst-case building air leakage and worst- case duct leakage. Such worst-caseparameters shall be used as inputs to the compliance software for energy analysis.

Reason: Sampling is a process of testing/evaluating one unit in a batch of 7 multiple like units to determine if all seven of the units w ould pass the intentof Code. The reality is that single family and attached housing, tow n houses and duplexes, are not like units even w hen they have the same modelnumber and have been built off of the same plan. Our construction processes are not true assembly line processes so for the purpose of codecompliance batch sampling should continue not to be allow ed for these types of housing.

Multifamily stacked housing, on the other hand, is basically one large building that has been subdivided into multiple smaller units. Batch sampling is idealfor this type of construction as each unit is a continuation of the unit adjacent to it, thus create the total building. When inspecting at rough you can costaffectively evaluate multiple units so in reality the sampling truly only comes into play for the f inal diagnostics (blow er door testing) and reporting.

Cost Impact: Will not increase the cost of constructionSampling of stacked multifamily units is more cost effective than testing each unit w hile at the same time ensuring that the inspection process for codecompliance is valid as intended.


RE143-16Table R405.5.2(1) [IRC Table N1105.5.2(1)] Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, representing Alliance to Save Energy; William Prindle, ICF International, representing EnergyEfficient Codes Coalition


TABLE R405.5.2(1) [(N1105.5.2(1)]SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS


Air Exchange Rate

Air leakage rater of 5 air changes per hour in Climate Zones 1 and 2,and 3 air changes perhour in Climate Zones 3 through 8 at a pressureof 0.2 inches w.g. (50 Pa). The mechanical v entilation rate shall be in

addition to the air leakage rate and the same as in the proposeddesign, but no greater than 0.01 × CFA + 7.5 × (Nbr + 1)

where: CFA = conditioned f loor areaNbr = number of bedrooms

Energy Recov ery shall not be assumed f or mechanical v entilation.

For residences that are not tested, the same air leakage rate as thestandard ref erence design. For tested residences, the The measured

air exchange ratea.

The mechanical v entilation rateb shall be in addition to the airleakage rate and shall be as proposed.




As proposed





Structural mass







As proposed


















h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area. As = Standard ref erence design total glazing area. FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions. Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit.


RE143-16 : R405.5.2-FAY12781

L and CFA are in the same units.

Reason: The purpose of this proposal is to remove an inconsistency in the code. Under section R402.4.1.2, testing is mandatory in all buildings. As aresult, the language in this table as to residences not tested is inconsistent and confusing. Moreover, the language implies that homes not tested w illautomatically comply w ith the air exchange rate requirements, since the assumption for the proposed design w ould be the same as that of the standardreference design. That is clearly not the intent of the IECC, and this proposal removes the conflicting language.

Cost Impact: Will not increase the cost of constructionSince the code requirements are not proposed to be changed, this proposal w ill not affect the cost of construction.


RE144-16Table R405.5.2(1) [IRC N1105.5.2(1)], R405.7 (New) [IRC N1105.7 (New)]Proponent : Craig Conner, representing self ([email protected])



Portions of Tab le not shown remain unchanged





As proposed





Structural mass


For masonry basement walls, as proposed, but with insulationrequired by Table R402.1.4 located on the interior side of the walls As proposed



As proposed f or other than electric heating without a heat pump,where the proposed design utilizes electric heating without a heat

pump the standard ref erence design shall be an air source heat pumpmeeting the requirements of Section C403 of the IECC-Commercial

Prov isions. Fuel ty pe: same as proposed design.

Ef f iciencies:

Electric: air-source heat pump with prev ailing f ederal minimumstandards.

Non-electric f urnaces: natural gas f urnace with prev ailing f ederalminimum standards.

Non-electric boilers: natural gas boiler with prev ailing f ederal minimumstandards.

Capacity : sized in accordance with Section R403.7.

As proposed


As proposed:Fuel ty pe: Electric

Ef f iciency : in accordance with prev ailing f ederal minimum standards

Capacity : sized in accordance with Section R403.7

As proposed

Serv ice water heatingd, e, f , g

As Proposed.


Fuel ty pe: same as proposed design

Ef f iciency : In accordance with prev ailing

f ederal minimum ef f iciency standards


















h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area.


RE144-16 : TABLE R405.5.2-CONNER12791

As = Standard ref erence design total glazing area. FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions. Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit. L and CFA are in the same units.


R405.7 (N1105.7) Equipment and device efficiency verification. The efficiency of the equipment and devices used for the proposed design shall be specified in the construction documents.The installed equipment and devices shall have an efficiencies not less than the efficiencies specified in the constructiondocuments. The efficiency of installed equipment and devices shall be determined from the manufacturer's label on theequipment or device or on a manufacturer's specification sheet that is attached to the equipment or device at inspection. Suchlabel or sheet shall be readily observable after the equipment or device is fully installed. This section shall apply only toequipment and devices where the proposed design is different than the standard reference design for that equipment or device.

Reason: This retains the energy neutral equipment trade-off provisions from the 2006 International Energy Conservation Code (IECC) for the heatingsystems, cooling systems, and service w ater heating. By retaining these, builders have an opportunity to optimize a code-compliant house designusing energy eff icient equipment. Quite often, high eff iciency equipment provides part of a cost effective solution to achieve code compliance. Including equipment eff icient encourages the "house as a system" approach, w hich is a cornerstone of building science.Not including equipment makes no sense in many areas. For example, Haw aiian energy eff icient design w ithout consideration of solar hot w ater makesno sense. As w orded now the code treats solar hot w ater as if it saved no energy. Eff icient air conditioning has a big impact in Haw aii. Why shouldthe IECC act as if it does not matter? Ground source heat pumps w ork w ell in many climates. Why should the code ignore ground source heat pumps? Utah recognizes energy eff icient in their energy code, as do other states. The commercial IECC and ASHRAE count equipment eff iciency tow ardsenergy savings.

Signif icant improvements in the eff iciency of HVAC and w ater heating equipment have been made in the last 20 years. The code should encourage andcredit the use of eff icient equipment.

In reference to the new language for R405.7, one big issue w ith having options for more eff icient equipment and devices is inspection and verif ication.The eff iciency used must be easy to verify. This new section, Section R405.7, requires that the eff iciency used in the proposed design be specif ied onconstruction documents. Any equipment or device that meets or exceeds the eff iciency marked on construction documents w ill be acceptable. Codeenforcement staff does not have the time to look up equipment or device model numbers to f ind an eff iciency rating in a data base or book; therefore,the new Section R405.7 requires that the installed eff iciency be "readily observable", w hich is very similar to "readily accessible". "Readily observable"is the term used in Section R303.1.2 and C303.1.2 for the insulation R-value.

Cost Impact: Will not increase the cost of constructionAvailability of more tradeoff options tend to decrease overall construction costs.


RE145-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Craig Conner, representing self ([email protected])



Portions of Tab le not shown remain unchanged.


Abov e-grade walls














Ceilings




Roof s











Vertical f enestration other than opaque doors

Total areah =




Orientation: equally distributed to f our cardinal compass orientations (N, E, S & W). As proposed







Air exchange rate

Air leakage rate of 5 air changes per hour in Climate Zones 1 and 2, and3 air changes per hour in Climate Zones 3 through 8 at a pressure of 0.2

inches w.g (50 Pa). The mechanical v entilation rate shall be in additionto the air leakage rate and the same as in the proposed design, but no

greater than 0.01 × CFA + 7.5 ×(Nbr + 1)where:

CFA = conditioned f loor area Nbr = number of bedrooms













RE145-16 : TABLE R405.5.2-CONNER12798





Reason: Keep it simple and usable. Simple is setting a specif ic w indow requirement and having it apply to the w hole performance approach, as isdone in the prescriptive approach. Simple is presuming that the glass area for the performance calculation is the same as the glass area in theproposed new home. Simple is removing unneeded calculations. This change also has the effect of allow ing changes from plans to the home asconstructed w ithout recalculation. As w indow s get more eff icient, the w indow area matters less. In some situations more glass better. In northern climates high quality w indow s arenearly as good as a "normal" w all. Therefore the impact of w indow area is decreased and not w orth the calculation.

Removal of the w indow area calculation w as the major simplif ication in the 2003 IECC simplif ication needed to get to the 2006 IECC. The 2006 IECCsimply says use as much w indow as you w ant, just make it energy eff icient w indow s. Requiring a specif ic w indow for each climate zone createdhuge markets for those specif ic levels of eff iciency. Window makers respond by making a energy eff icient w indow s a commodity, w ith a signif icantfall in the cost for energy eff icient w indow s. The effect has been so strong that the building code has repeatedly pushed Energy Star to move to newlevels.

Cost Impact: Will not increase the cost of constructionHaving the reference design house w ith the same w indow area as the proposed house makes tradeoff w ork better. It may slightly low er costs.


RE146-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Tom Kositzky, Coalition for Fair Energy Codes, representing Coalition for Fair Energy Codes; Mark Halverson,representing APA ([email protected]); Loren Ross, representing TBD ([email protected])

2015 International Energy Conservation Code


Portions of Tab le not shown remain unchangedBUILDING COMPONENT STANDARD REFERENCE DESIGN PROPOSED DESIGN

Abov e-grade walls














Ceilings




Roof s












Total areah =











Air exchange rate

















RE146-16 : TABLE R405.5.2-KOSITZKY12442





Reason: While typically only 15% of the f loor area, fenestrations account for over 50% of the UA of envelope w alls, so even small changes infenestration area result in large changes in w all energy eff iciency. It is only logical that the code recognize the savings from smaller glazing area viathe performance path.

Currently, providing glazing area greater than 15% of the f loor area is penalized for its reduced energy eff iciency. This makes sense; more use of lesseff icient w all components creates a penalty.

How ever, reducing glazing area to less than 15% of the f loor area is not rew arded for increasing energy eff iciency. This does not make sense;increased use of more eff icient w all components should be rew arded.

The thermal performance of code-conforming w indow s is not comparable to opaque w alls. In the 2015 IECC-R, w alls are typically 6 times more energyeff icient than w indow s. The least insulated opaque w alls (Climate Zone 1) are more than 4 times more eff icient than the w indow s required in thecoldest climate zone (Climate Zone 8).

a. Table R402.1.4 Equivalent U-factors

Even w ith the current proposals to low er the w indow U-factors, there is no indication that w indow U-factors w ill approach the U-factors ofopaque w alls in the near term.

The IECC must recognize and encourage the option of less glazed area as a core principle of energy eff icient buildings.

Cost Impact: Will not increase the cost of constructionThis proposal makes modif ications to Table R405.5.2(1) w hich establishes criteria for how proposed residential designs w ill be analyzed to determineenergy eff iciency. The proposal does not increase or change the standard reference glazing area of 15% of conditioned f loor area. If it did, it couldresult in higher construction costs. Instead it merely recognizes that a proposed glazing area that is less than 15% of conditioned f loor area, results inadditional energy savings. This is in keeping w ith a true performance path approach and as such w ill not increase the cost of construction.


RE147-16Table R405.5.2(1) [IRC IRC N1105.5.2(1)]Proponent : Neil Leslie, Gas Technology Institute ([email protected])







As proposed





Structural mass





As proposed f or other than electric heating without a heat pump, wherethe proposed design utilizes electric heating without a heat pump thestandard ref erence design shall be anaAir source heat pump meeting


As proposed

Cooling sy stemsd, f eAs proposedAir source heat pump meeting the requirements of

Section C403 of the IECC-Commercial Prov isions. Capacity : sized inaccordance with Section R403.7.

As proposed

Serv ice water heating d, e, f , gAs proposedElectric resistance water heater meeting the requirements

of Section C404 of the IECC-Commercial Prov isions.Use: same as proposed design













e d. For a proposed design without a proposed heating sy stem, a heating sy stem an electric heat pump with the prev ailing f ederal minimum ef f iciency shall be assumed f orboth the standard ref erence design and proposed design.

f e. For a proposed design home without a proposed cooling sy stem, an electric air conditioner with the prev ailing f ederal minimum ef f iciency shall be assumed f or both thestandard ref erence design and the proposed design.

g f . For a proposed design with a nonstorage-ty pe water heater, a 40-gallon storage-ty pe electric resistance water heater with the prev ailing f ederal minimum energy f actorf or the same f uel as the predominant heating f uel ty pe shall be assumed. For the case of a proposed design without a proposed water heater, a 40-gallon storage-ty pe electric resistance water heater with the prev ailing f ederal minimum ef f iciency f or the same f uel as the predominant heating f uel ty pe shall be assumed f or both theproposed design and standard ref erence design.

h g. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area. As = Standard ref erence design total glazing area. FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions. Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit. L and CFA are in the same units.

Reason: The IECC has already chosen the right metrics for energy performance in Section R405.3:

1. Energy cost budget (for adopting authorities mainly concerned about the homeow ner's economic objectives), or2. Source energy budget (for adopting authorities mainly concerned about the homeow ner's energy consumption impacts on primary energy

consumption).

How ever, for these to be implemented in an equitable manner, one critical additional step is needed: A single reference building energy budget. Thisamendment provides the critical single reference budget methodology to implement this code more equitably. It is only by implementing the correctmetrics correctly - i.e. through the single reference building methodology – that the IECC can avoid adverse effects and unintended consequences of


RE147-16 : TABLE R405.5.2-LESLIE11072

the code that are otherw ise imposed on users.

The revised tables and text completely decouple the proposed building design choices from the standard reference design building's energy cost orsource energy performance requirement. The reference energy and technology choices in the revised section w ere selected to provide apractical minimum performance requirement to meet the intent of the standard w hile still offering appropriate incentives for the best availabletechnologies based on their energy cost or source energy benefits. By shifting to electric technologies for all reference mechanical systems, thisamendment allow s determination of an equitable energy cost or source energy budget at a reasonable level of performance using compliant electrictechnology options that are alw ays available for consideration and comparsons in any new home design.

This proposal incorporates the same single reference building methodology used in ASHRAE Standard 90.1-2013 performance path in NormativeAppendix G (a compliance pathw ay in the IECC commercial code). By including the proposed methodology in the residential provisions of the 2018 IECC,the residential and commercial perforance path provisions w ill be internally consistent.

Cost Impact: Will not increase the cost of constructionThe proposal is likely to reduce the cost of construction compared to the current code language that is silent on the benefits of equipment eff iciencyimprovements except for electric heating systems. By permitting fuel and technology-agnostic tradeoffs w ith other technology options and buildingcomponents, this proposal w ill enable designers to select the most affordable and cost-effective components and systems to meet the energyperformance requirements under this path of the code. It is the path to equitable least cost energy eff iciency planning that benefits the builder,consumer, and society.

Analysis: Screen 1 of Table is not show n for clarity, how ever, the re-lettering of notes by the proponent w ill result in a letter change (h to g) for oneitem in Screen 1.


RE148-16Table R405.5.2 (1) [IRC Table N1105.5.2 (1)]Proponent : Robert Lucas, representing self ([email protected])







As proposed





Structural mass







Prov isions.

Fuel ty pe: same as proposed design

Ef f iciencies:

Electric: air-source heat pump comply ing with prev ailing f ederalminimum standards

Gas f urnaces: natural gas f urnace hav ing a 90% Annual FuelUtilization Ef f iciency

Oil f urnaces: Oil f urnace comply ing with prev ailing f ederal minimumstandards

Nonelectric boilers: natural gas boiler comply ing with prev ailingf ederal minimum standards

Other: As proposed


As proposed


As proposedFuel ty pe: Electric

Ef f iciency : Comply ing with prev ailing f ederal minimum standards

Capacity : sized in accordance with Section R403.7.

As proposed

















h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area. As = Standard ref erence design total glazing area.


RE148-16 : TABLE R405.5.2-LUCAS12931

FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions. Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit. L and CFA are in the same units.

Reason: The IECC has alw ays contained the performance based perspective that a home design complies as long as the home design resulted in aprojected overall energy use equal to or less than the projected energy use for the same home built w ith IECC prescriptive requirements. For the 2006IECC and before, the code traditionally allow ed credit in the performance approach for improvements in heating and cooling system eff iciency thatexceeded US. Department of Energy (DOE) equipment manufacturing standards. (The U.S. DOE regulates national minimum eff iciencies for commonhousehold equipment including space heating, cooling, and domestic w ater heating equipment.)Over time, DOE minimum equipment standards w ere not updated and began lagging behind free market improvements to equipment eff iciency. Thismeant that the builder or designer could often get a "free rider" extra credit in the performance path for simply selecting equipment that could fairly becalled standard practice in their locale. This credit allow ed other energy eff iciency measures such as insulation the home to be somew hat w atereddow n to be below IECC prescriptive minimums. This is a primary reason that the ICC decided to eliminate the trade-off credit for heating and coolingequipment improvements from the performance path starting in the 2009 IECC.

Since the removal of the equipment trade-off credit in the 2009 IECC, DOE has had success in updating several national equipment standards. Central airconditioners w ere recently updated to 14 SEER in the southern part of the nation, w ith a 13 SEER minimum in the north. Similarly, residential sized heatpump and boiler equipment standards have been recently updated. Because the DOE standards have raised the bar for the baseline for w hichimproved equipment begins to get trade-off credit, it is reasonable to reconsider allow ing the equipment trade-offs again in the performance path.

How ever, there is one very notable exception w here DOE minimum eff iciency standards are not appropriate for a baseline. The DOE standards forresidential natural gas furnace eff iciency standards have not had a meaningful update since 1992. The DOE gas furnace standards w ill lag behind 26years of progress by the time the 2018 IECC is issued. My proposal today sets a trade-off baseline of 90% AFUE. This is consistent w ith a keyagreement set on October 13, 2009 by the Air Conditioning, Heating, and Refrigeration Institute and energy eff iciency advocates(http://w w w .achrnew s.com/articles/123056-regional-standards-timeline). These gas furnace eff iciency levels w ere then proposed by DOE in anupdated rulemaking that w as w ithdraw n in 2013 for reasons that are not relevant to this proposed code change. Given the w idespread usage of 90%eff iciency condensing gas furnaces today in new homes particularly in the colder states, it is entirely reasonable to set the baseline for performancetrade-offs to 90% despite the fact DOE's proposal update to this level in equipment standards failed. To be conservative, I have proposed setting the90% AFUE to be the baseline in all states. It is important to understand this proposal has absolutely no disadvantage in the code for home designs w itha gas furnace having an eff iciency of less than 90%.

One major argument used in previous IECC development hearings against crediting improved equipment in the performance path is that equipment has asomew hat shorter average lifetime than other major energy eff iciency measures such as insulation and fenestration. There is some validity in thisargument, but there is a lack of compelling evidence to not allow any credit for equipment. Notably, w indow s certainly don't last forever and may bereplaced almost as often as heating and cooling equipment. Just as important, w indow s (and other building envelope measures) w ill tend to developsome degree of air leakage over the long run, undercutting the energy eff iciency of these measures even if they are not replaced. Even insulation cancompress, settle, be jostled, displaced, or otherw ise lose some degree of effectiveness over the course of decades. Furthermore, envelope measurescan eventually be replaced if a major renovation occurs. This proposal does not allow trade-off credit for domestic w ater heating equipment as thelifetime of this equipment can be as little as a decade or even less. The bottom line is all energy eff iciency measures have variable lifetimes and longterm effectiveness. If the ICC development community is unw illing to accept this variability, the performance path should probably be eliminated in itsentirety.

One f inal observation. The landscape has changed since the equipment tradeoff credit w as removed from the IECC. Specif ically, there have been majorimprovements to envelope measure stringency in the IECC resulting from the 2009 and 2012 code change cycles coupled w ith the updated DOEequipment standards and the 90% gas furnace baseline set in this proposal. These developments mean that the concerns about w eak envelopemeasures resulting from improved equipment trade-off credits are largely unfounded. There is simply not enough credit available for this to happen inthe vast majority of cases.

Cost Impact: Will not increase the cost of constructionNo existing code requirements are increased in stringency in any w ay. This proposal only increases options in the performance path.


RE149-16Table R405.5.2 [IRC Table N1105.5.2(1)]Proponent : Mike Moore, Newport - Representing Broan-NuTone, representing Broan-NuTone ([email protected])






0.03942 × CFA + 29.565 × (Nbr +1)(1/ef ) × (0.0876 × CFA + 65.7 × (Nbr+1))

where:CFA = conditioned f loor area, Nbr = number of bedrooms, andef = the minimum exhaust f an ef f icacy f rom Table R403.6.1corresponding to a f low rate of 0.01 × CFA + 7.5 × (Nbr+1))

As proposed





Structural mass







As proposed



















Reason: Currently, the equation used for the reference home in Table R405.5.2(1) assumes continuous operation of the w hole house mechanicalventilation system (i.e., 8760 hours/year) and a f ixed fan eff icacy of 2.2 cfm/W, w hich is not supported by the fan eff icacy requirements in TableR403.6.1. This change w ill keep the table current by allow ing the fan eff icacy of the reference home to track w ith any future changes to the w holehouse mechanical ventilation fan eff icacy requirements in Table R403.6.1. Example:


RE149-16 : TABLE R405.5.2-MOORE11088

The proposed equation is equivalent to the current equation if w e use 2.2 cfm/W for the fan eff icacy:

Proposed equation = (1/ef ) × (0.0876 × CFA + 65.7 × (Nbr+1))

Substituting ef= 2.2 yields: (1/2.2) × (0.0876 × CFA + 65.7 × (Nbr+1)) = 0.03942 × CFA + 29.565 × (Nbr+1) = the current equation

Cost Impact: Will not increase the cost of constructionThis change simply corrects the equation for the energy calculation of the mechanical ventilation system. There is no effect on system cost.


RE150-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Donald Surrena ([email protected])



(Portions of Tab le not shown remain unchanged.)


Vertical f enestration other thanopaque doors

Total Areab = (a) The proposed glazing area, where proposed glazing area is less

than 15% of the conditioned f loor area.(b) 15% of the conditioned f loor area, where the proposed glazing area

is 15% or more of the conditioned f loor area.Orientation: equally distributed to f our cardinal compass orientations

(N E S & W)Orientation: equally distributed to f our cardinal compass

orientations (N, E, S, & W)U-f actor: f rom Table R402.1.3

SHGC: From Table R402.1.1 except that f or climates with norequirement (NR) SHGC = 0.40 shall be used.

Interior shade f raction: 0.92-(0.21 × SHGC f or the standard ref erencedesign)

External shading: none

As proposed

As proposed

As proposedAs proposed

0.92-(0.21 × SHGC asproposed)

As proposed




As proposed





Structural mass







As proposed


















h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF = A s x FA x Fwhere: AF = Total glazing area. As = Standard ref erence design total glazing area. FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area). F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater. and where: Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions.



Below-grade boundary wall is any thermal boundary wall in soil contact. Common wall area is the area of walls shared with an adjoining dwelling unit. L and CFA are in the same units.

Reason: Walls generally have better thermal performance than w indow s. There is no incentive in the performance path for the building designer tooptimize the w indow area to save energy and provide daylighting, egress and view s that makes for a safe and comfortable house. These modif icationsw ill provide the building designer the ability to reduce w indow area and get credit for the energy saved. As this section is now w ritten, the house ispenalized for having more than 15% w indow area yet receives no credit tow ard code compliance w hen the w indow area is reduced below 15%. Thischange rectif ies this disparity and makes the performance path more representative of actual energy use.

Cost Impact: Will not increase the cost of constructionThe code change proposal w ill add options and have the potential to reduce the cost of construction w hile acknow ledging more w ays to achievecompliance and eff iciency.


RE151-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Marilyn Williams, NEMA, representing National Electrical Manufacturers Assocation ([email protected])



In the Air Exchange Rate Row, in the STANDARD REFERENCEDESIGN COLUMN, add the following after"....zones 1 and 2 (3 airchanges per hour when using a non-ducted heating system), 3 airchanges per hour......





As proposed





Structural mass







As proposed



















Reason: Energy losses through ductw ork are recognized as signif icant and come from tw o distinct sources; air lost through ductw ork to the outsideand, separately, induced inf iltration/exfiltration caused by duct pressurization. Air lost to the outside is self-explanatory and is, in fact, alreadyrecognized by the 2015 IECC (and earlier versions) in Table R405.5.2(2) w here distribution system eff iciency is discounted under certain common



conditions. In addition, there is grow ning recognition that ductw ork design can have a signif icant impact on inf iltration/exfiltration. On this basis, areasonable person could conclude that, all other things being held constant, a non-ducted ERH system w ould consume less energy than a ductedelectric furnace. This proposal recognizes the reduced inf iltration impact of using non-ducted space heating.

Cost Impact: Will not increase the cost of constructionThis proposal does not require the purchase of any additional materials and or the expenditure of any additional labor, accordingly, it w ill have no impacton the cost of construction.


RE152-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Marilyn Williams, NEMA, representing National Electrical Manufacturers Association ([email protected])


TABLE R405.5.2 (1) [N1105.5.2(1)]SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS


Abov e-grade walls














Ceilings




Roof s












Total areab =











Air exchange rate















As proposed





Structural mass





For other walls, f or ceilings, f loors, and interior walls, wood f rameconstruction

As proposed




Prov isions. Capacity : sized in accordance with Section R403.7

As proposed





Duct insulation: From Section R403.2.1, a thermal distributionsy stem ef f iciency (DSE) of 0.88 shall be applied to both the heating

and cooling sy stem ef f iciencies f or all sy stems other than testedduct sy stems.

Exception: For non-ducted heating and cooling sy stems not hav ing af an, the standard ref erence design distribution sy stem ef f iciency

(DSE) shall be 1.

For tested duct sy stems, the leakage rate shall be 4 cf m (113.3

L/min) per 100 f t2 (9.29 m2 ) of conditionedfloor area at a pressure ofdif f erential of 0.1 inches w.g. (25 Pa).




a. Where required by the code official , testing shall be conducted by an approved party . Hourly calculations as specif ied in the ASHRAE Handbook of Fundamentals , orthe equiv alent shall be used to determine the energy loads resulting f rom inf iltration.

b. The combined air exchange rate f or inf iltration and mechanical v entilation shall be determined in accordance with Equation 43 of 2001 ASHRAE Handbook ofFundamentals , page 26.24 and the "Whole-house Ventilation" prov isions of 2001 ASHRAE Handbook of Fundamentals , page 26.19 f or intermittent mechanical v entilation.

c. Thermal storage element shall mean a component not part of the f loors, walls or ceilings that is part of a passiv e solar sy stem, and that prov ides thermal storage suchas enclosed water columns, rock beds, or phase-change containers. A thermal storage element must be in the same room as f enestration that f aces within 15 degrees (0.26rad) of true south, or must be connected to such a room with pipes or ducts that allow the element to be activ ely charged.

d. For a proposed design with multiple heating, cooling or water heating sy stems using dif f erent f uel ty pes, the applicable standard ref erence design sy stem capacitiesand f uel ty pes shall be weighted in accordance with their respectiv e loads as calculated by accepted engineering practice f or each equipment and f uel ty pe present.



g. For a proposed design with a nonstorage-ty pe water heater, a 40-gallon storage-ty pe water heater with the prev ailing f ederal minimum energy f actor f or the same f uelas the predominant heating f uel ty pe shall be assumed. For the case of a proposed design without a proposed water heater, a 40-gallon storage-ty pe water heater with theprev ailing f ederal minimum ef f iciency f or the same f uel as the predominant heating f uel ty pe shall be assumed f or both the proposed design and standard ref erence design.

h. For residences with conditioned basements, R-2 and R-4 residences and townhouses, the f ollowing f ormula shall be used to determine glazing area: AF

AF = Ass xFA FA xF Fwhere:AF = Total glazing area.As = Standard ref erence design total glazing area.FA = (Abov e-grade thermal boundary gross wall area)/abov e-grade boundary wall area + .0.5 x below-grade boundary wall area).F = (Abov e-grade thermal boundary wall area)/(abov e-grade thermal boundary wall area + common wall area) or 0.56, whichev er is greater.and where:Thermal Boundary wall is any wall that separates conditioned space f rom unconditioned space or ambient conditions.Below-grade boundary wall is any thermal boundary wall in soil contact.Common wall area is the area of walls shared with an adjoining dwelling unit.L and CFA are in the same units.

Reason: Space heating systems that operate w ithout consuming fan energy and that do not have ductw ork (no duct losses) do not have distributionsystem losses and this proposal w ould simply change the code to factually recognize that reality.



RE153-16R202 (IRC N1101.6) (New), Table R405.5.2 (IRC Table N1105.5.2)Proponent : Marilyn Williams, NEMA, representing National Electrical Manufacturers Association ([email protected])


R202 (N1101.6) GRID-INTERACTIVE ELECTRIC STORAGE SYSTEMS (GETS) An energy storage system that provideselectric system grid operators such as utilities, independent servce operators (ISOs), or regional transmission organizations(RTOs) with variable control of a building's space and water heating end uses to assist in the real-time balancing of energysupply and demand on the electric grid and integration of renewable energy from solar and wind while providing low cost spaceand water heat for consumers.

Revise as follows:

TABLE R405.5.2 R405.5.2(1) [N1105.5.2(1)] (1) SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS







As proposed



Internal massAn internal mass f or f urniture and contents of 8 pounds per square

f oot of f loor area.






air.

As proposed


required by Table R402.1.4 located on the interior side of the walls

As proposed


construction

As proposed






Commercial Prov isions.Capacity : sized in accordance with Section

R403.7

As proposed




As proposed

gal/day = 30 + (10 × Nbr )

Thermal distribution sy stems Duct insulation: From Section R403.2.1A thermal distribution

sy stem ef f iciency (DSE) of 0.88 shall be applied to both the

heating and cooling sy stem ef f iciencies f or all sy stems other than

tested duct sy stems. For tested duct sy stems, the leakage rate

shall be 4 cf m (113.3 L/min) per 100 f t2 (9.29 m2 ) of

As tested or as specif ied in Table R405.5.2(2) if not tested. Duct

insulation shall be as proposed.




w.g. (25 Pa).

Exception: Where the proposed design is f or an electric heating

sy stem that is grid-interactiv e electric thermal storage (GETS), the

standard ref erence design shall be as proposed.












Reason: Grid-Interactive ELectric Thermal Storage is an innovative approach to space and w ater heating w ith a grow ing reputation among marketparticipants as a solution to some of today's most pressing energy issues.1. Building ow ners like GETS because it provides affordable and dependable space and service w ater heating for their structurs.

2. Electric grid operators like GETS because it helps them balance energy supply and demand in real time, thereby increasing grid stability w hilesimultaneously reducing costs, energy and emissions. Maintaining grid stability becomes more challenging as the output of renew able energygeneration (like w ind and solar) is added to electric grids w hich explains w hy grid operators across the country (as w ell as the Federal EnergyRegulatory Commission and the U.S. Department of Energy) have expressed their support for energy storage.

3. Renew able energy developers like GETS because it complements their products by providing cost-effective energy storage w hen renew ableenergy production exceeds demand. Without adequate energy storage, these projects are often curtailed.



RE154-16Table R405.5.2(1) [IRC Table N1105.5.2(1)]Proponent : Marilyn Williams, NEMA, representing National Electrical Manufacturers Association ([email protected])


TABLE R405.5.2 [N1105.5.5(1)] (1) SPECIFICATIONS FOR THE STANDARD REFERENCE AND PROPOSED DESIGNS







As proposed



Internal massAn internal mass f or f urniture and contents of 8 pounds per

square f oot of f loor area.






air.

As proposed


required by Table R402.1.4 located on the interior side of the walls

As proposed


construction

As proposed






Commercial Prov isions.the minimum ef f icency requirements of

Tables C403.2.3(1), C403.2.3(2), C403.2.3(3), C403.2.3(4),

C403.2.3(5), C403.2.3(6), C403.2.3(7), C403.2.3(8) and

C403.2.3(9), as applicable, when tested and rated in accordance

with the applicable test procedure. Where the proposed design is

f or an electric heating sy stem that does not use a duct sy stem,

the standard ref erence design shall be as proposed.


As proposed




As proposed

gal/day = 30 + (10 × Nbr )

Thermal distribution sy stems Duct insulation: From Section R403.2.1A thermal distribution

sy stem ef f iciency (DSE) of 0.88 shall be applied to both the

heating and cooling sy stem ef f iciencies f or all sy stems other

As tested or as specif ied in Table R405.5.2(2) if not tested. Duct

insulation shall be as proposed.



than tested duct sy stems. For tested duct sy stems, the leakage

rate shall be 4 cf m (113.3 L/min) per 100 f t2 (9.29 m2 ) of


w.g. (25 Pa).












Reason: As it is w ritten, Table R405.5.2(1) requires a modeler to assume a heat pump system w henever a designer proposes to use "... other thanelectric heating w ithout a heat pump," i.e., electric resistance or electric radiant heating (collectively "ERH") in a new residence. While perhaps serving avaluable function in some fashion (elimination of gaming w here a modeler assumes an electric furnace for the reference house and then proposes aheat pump allow ing a less stringent envelope), the limitation on use of ERH in the modeling is overly restrictive. ERH is available in many differentapplications and the performance characteristics of non-ducted ERH are very dif ferent from the performance characteristics of ducted heatingsystems, w hether fueled by electricity, gas, or any other fuel. In addition to no duct energy losses, non-ducted ERH also enjoys signif icant energysavings from zoning. This proposal attempts to preserve the benefit of eliminating gaming w hile still recognizing the energy savings potential of non-ducted ERH. In addition, this proposal cites the heat pump specif ic provisions of the IECC commercial provisions rather than simply citing the commercialchapter.

DYNICE-Put Attachement HERE.



RE155-16R401.2 (IRC N1101.13), R406 (IRC N1106)Proponent : Craig Conner, representing self ([email protected]); Kendra Cardinale, representing BuildingQuality ([email protected])


SECTION R406 ENERGY RATING INDEX COMPLIANCE ALTERNATIVE

R406.1 Scope. This section establishes criteria for compliance using an Energy Rating Index (ERI) analysis.

R406.2 Mandatory requirements. Compliance with this section requires that the provisions identified in Sections R401through R404 labeled as "mandatory" and Section R40.5.3 be met. The building thermal envelope shall be greater than or equalto levels of efficiency and Solar Heat Gain Coefficient in Table 402.1.1 or 402.1.3 of the 2009 International Energy ConservationCode.


R406.3 Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on a linearscale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses no netpurchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the totalenergy use of the rated design relative to the total energy use of the ERI reference design. The ERI shall consider all energyused in the residential building.

R406.3.1 ERI reference design. The ERI reference design shall be configured such that it meets the minimum requirementsof the 2006 International Energy Conservation Code prescriptive requirements.


R406.4 ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown to have anERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERIreference design.

R406.4 MAXIMUM ENERGY RATING INDEX


1 52

2 52

3 51

4 54

5 55

6 54

7 53

8 53

R406.5 Verification by approved agency. Verification of compliance with Section R406 shall be completed by an approvedthird party.

R406.6 Documentation. Documentation of the software used to determine the ERI and the parameters for the residentialbuilding shall be in accordance with Sections R406.6.1 through R406.6.3.

R406.6.1 Compliance software tools. Documentation verifying that the methods and accuracy of the compliance softwaretools conform to the provisions of this section shall be provided to the code official.

R406.6.2 Compliance report. Compliance software tools shall generate a report that documents that the ERI of the rateddesign complies with Sections R406.3 and R406.4. The compliance documentation shall include the following information:

1. Address or other identification of the residential building.


RE155-16 : R406-CONNER13513

2. An inspection checklist documenting the building component characteristics of the rated design. The inspectionchecklist shall show results for both the ERI reference design and the rated design, and shall document all inputsentered by the user necessary to reproduce the results.



R406.6.3 Additional documentation. The code official shall be permitted to require the following documents:


R406.7 Calculation software tools. Calculation software, where used, shall be in accordance with Sections R406.7.1through R406.7.3.

R406.7.1 Minimum capabilities. Calculation procedures used to comply with this section shall be software tools capable ofcalculating the ERI as described in Section R406.3, and shall include the following capabilities:


2. Calculation of whole building, as a single zone, sizing for the heating and cooling equipment in the ERI referencedesign residence in accordance with Section R403.7.



R406.7.2 Specific approval. Performance analysis tools meeting the applicable sections of Section R406 shall be approved.Tools are permitted to be approved based on meeting a specified threshold for a jurisdiction. The code official shall approvetools for a specified application or limited scope.

R406.7.3 Input values. When calculations require input values not specified by Sections R402, R403, R404 and R405, thoseinput values shall be taken from an approved source.

Revise as follows:


1. Sections R401 through R404.2. Section R405 and the provisions of Sections R401 through R404 labeled "Mandatory."3. An energy rating index (ERI) approach in Section R406.

Reason: When one adds up all the requirements in the ERI and looks for other w ays to do the same thing, there are none as the code exists now . Either other methods of providing a similar function, allow ing broad based tradeoffs in the energy code, should be provided or the ERI should bedeleted. Either the IECC allow s several methods of doing w hole house tradeoffs, such that many programs can play, or it is setting up the IECC to beproprietary. If the bottom line is equal energy use, w hat are the unnecessary requirements?

1. Use of the normalized modif ied load, w hich w ill be proposed to point to RESNET's calculation, including Section 4.1.1 of RESNET's standards. Who uses that besides RESNET and RESNET associated parties? Most use energy cost instead.

2. Is the 100 point scale necessary, or do others use different scales to accomplish the same goal. Other scales w ould w ork just as w ell.3. Does the scale have to be declining. No. Some have ascending scales.4. Does the scale have to be based on the 2006 IECC. No. Others have different base cases. The 2006 w ill be more than 10 years old w hen the

2018 IECC is out.5. Does the calculation need to include "All energy used in the residential building."? No, and this is unusual because it w ould include energy used

in w ays not regulated by the code, for example energy used by devices plugged into the w all outlets.

Further the performance option in the code has been disabled by eliminating options such as trading off equipment eff iciency and air tightness. Whilethe ERI, could, and does include in RESNETS case tradeoffs for equipment, air tightness, and a range of items. For example refrigerators, dishw ashers,lighting, ....

There are proposals to create a more level playing f ield. If these fail, the code should not crow n one organization as the w inner and the ERI should bedeleted.

Cost Impact: Will not increase the cost of constructionAs listed in the code now , it is hard to argue that the ERI is anything but a signif icant cost increase, although it is still an option. The least cost approachw ould bring others to compete w ith RESNET to provide the same service for a broad based energy tradeoff.


RE156-16 : R406.2-DRUMHELLER13004

RE156-16R406.2 (IRC N1106.2)Proponent : Craig Drumheller ([email protected])


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R40.5.3 be met. The proposed total building thermal envelope UAwhich is sum of U-factor times assembly area, shall be less than or equal to the building thermal envelope UA using theprescriptive U-factors from Table R402.1.2 multiplied by 1.15 in accordance with Equation 4-1. Supply and return ducts notcompletely inside the building thermal envelope shall be greater insulated to a R-value of not less than or equal to levels ofefficiency and Solar Heat Gain Coefficient in Table 402.1.1 or 402.1.3 of the 2009 International Energy Conservation CodeR-6.


UAproposed design<=1.15*UAprescriptive reference design Equation 4-1

Reason: This proposal increases the f lexibility of the thermal envelope minimums that are part of the new ERI compliance path mandatory requirementsin the 2015 IECC. The minimum thermal envelope requirements are that of the 2009 IECC prescriptive table. While this could be considered a reasonable"backstop", the f lexibility it offers is minimal; for example both the 2009 and 2012 IECC require R-20 w alls in climate zone 5 and because the 2009 IECC isthe minimum, there is no ability to trade off w all insulation in climate zone 5, but w all insulation can be traded of in zones 4 and 6 since the w all insulationrequirements increased from the 2009 to the 2012. This proposal preserves this "reasonable envelope" concept and applies it to the ERI, but, rather than pointing to the prescriptive tables in a previousversion of the IECC, the thermal backstop becomes a percent UA trade-off. The UA calculation w ill be performed internally w ith the compliancesoftw are and w ill not require any additional information to be entered as all the necessary information is already entered (component area and U-factors/R-values). This should not be problematic as it is already done for w indow s.

The proposed UA trade-off of 15% should be considered a reasonable envelope backstop and is on par w ith the assumption that the 2012 IECC isroughly 15% more eff icient than the 2009 IECC. This 15% w ill prevent installing single pane w indow s and signif icant reductions in the building envelopecomponents (e.g. going from R20+5 w alls to R-13).

Cost Impact: Will not increase the cost of constructionThe increased f lexibility offered by this proposal w ill provide an opportunity for builders and designers to cost optimize an eff icient home and potentiallyreduce the cost of construction.


RE157-16 : R406.2-FAY12412

RE157-16R406.2 (IRC N1106.2)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, representing Alliance to Save Energy; William Prindle, ICF International, representing EnergyEfficient Codes Coalition


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R40.5.3 R403.5.3 shall be met. Fenestration U-factor and SHGC shallnot exceed the maximum values for the climate zone set forth in Table R402.1.2. The remaining components of the buildingthermal envelope shall be greater than comply with either the minimum R-values or equal to levels of efficiency and Solar HeatGain Coefficient maximum U-factors for the climate zones specified in Table 402.1.1 or 402.1.3 of the 2009 International EnergyConservation Code. R402.1.2 and R402.1.4.


Reason: The primary purpose of this code change proposal is to clarify, improve and update the mandatory requirements (for the thermal envelopeunder the ERI compliance alternative) in section R406.2, w hich are currently based on the 2009 IECC prescriptive requirements, to the current coderequirements, thereby ensuring a reasonable updated thermal envelope for those w ho use the ERI compliance path. Specif ically, this proposal improvesthe Energy Rating Index compliance option in three distinct w ays:

The proposal replaces an external reference to the prescriptive tables of the 2009 IECC w ith an internal section reference to the prescriptivetables of the current IECC, eliminating the need for code users to refer to tw o different editions of the IECC (w hich, by the publication date of the2018 IECC, w ill be roughly 9 years apart). It should be noted that the 2012 and 2015 prescriptive tables are largely the same, so that unlessthere is a substantial increase in stringency in this cycle, using the current code values w ould basically ref lect prescriptive thermal envelopevalues in place since the 2012 edition.The proposal w ill ensure that the permanent thermal envelope of homes built to the ERI path is essentially equivalent to homes built to the othercompliance options in the 2018 IECC. In cases w here this improved thermal envelope backstop results in more eff icient thermal envelopes,these improvements have been demonstrated to be cost effective, and w ill increase energy cost savings for homeow ners over the usefullifetime of the home. This backstop is particularly important given the broad scope of the ERI, w hich covers all energy use in the home, includingappliances, equipment and other features not included in other code compliance paths. These other components, many w ith much shorteruseful lives, represent a signif icant risk for trade-off against the thermal envelope (w hich w ill last much longer) to the detriment of long-termenergy savings, absent a strong backstop.The proposal clarif ies the applicability of the thermal envelope backstop requirements in section R406.2 by referencing the specif ic tables foreach type of thermal envelope component. The proposal also clarif ies that code users must use the specif ic requirements applicable to thespecif ic climate zone.

The intent of the IECC (section R101.3) is to "regulate the design and construction of buildings for the effective use and conservation of energy over theuseful life of each building." It is w ell understood that the eff iciency of the permanent thermal envelope is crucial to a home's performance over itsexpected very long useful lifetime. That w as the reason for putting this backstop to the ERI calculation in the code in the f irst place. Incrementalimprovements to the thermal envelope are far more cost-effective at construction than they are after the home is built. The purpose of the IECC, like thatof all International Codes, is to protect and benefit the ow ners and occupants of buildings. The improvement of the thermal envelope backstop in the ERIw ill result in less energy usage and low er costs, w hile helping make homes more comfortable, more resilient, and more secure investments forhomeow ners, and reducing peak demand and equipment sizing. It should be noted that comfortable homes are a key to energy eff iciency, sinceoccupants are likely to modify thermostat settings and use even more energy if uncomfortable due to w eak thermal envelopes.

Cost Impact: Will not increase the cost of constructionBecause Section R406.2 serves only as a backstop to ensure a minimum thermal envelope, and the backstop is incorporated into an optional compliancepath (ERI), this proposal does not require the builder to incur additional cost (the builder has the potential to incur additional cost only if the builderselects this compliance path). Moreover, since this section does not require overall eff iciency beyond that w hich is required in Section R406.3, the costimpact even w here this path is used is entirely dependent on design choices made by the builder. For example, if the builder has already met orexceeded the prescriptive thermal envelope requirements of the IECC in achieving the prescribed ERI, as is likely in many cases, then the thermalenvelope backstop in Section R406.2 w ill have no cost impact. By contrast, if the builder w ould have built the thermal envelope to the current minimumbackstop, and offset the difference by improving other components of the building in order to achieve the requisite ERI score, the cost impact w illdepend on w hether the upgrades to non-envelope components cost more or less than the envelope improvements w ould have cost.We note, how ever, that the prescriptive improvements made to the IECC betw een 2009 and 2015 (w hich are the basis for the backstop) have beendemonstrated to be cost-effective to the consumer – irrespective of other trade-offs that may take place. The U.S. DOE found that over a 30-yearuseful lifetime, an ow ner of a home built to the prescriptive and mandatory measures of the 2015 IECC (as compared to the 2009 IECC) could savebetw een $4,418 and $24,003 in energy costs, depending on climate zone. See V. Mendon, et. al., Pacif ic Northw est National Laboratory, National Cost-Effectiveness of the Residential Provisions of the 2015 IECC, at iv (June 2015),https://w w w .energycodes.gov/sites/default/f iles/documents/2015IECC_CE_Residential.pdf. These f igures include the presumed costs of the upgradesover the 2009 IECC. DOE also found that homeow ners w ould achieve a positive cash f low w ithin the f irst tw o years in every climate zone. Id. at v. Theanalysis show s an estimated simple payback period that ranges betw een 2.2 years and 8.1 years, again depending on climate zone. Id.

Thus, if the improved thermal envelope requires builders to incorporate improvements to the thermal envelope consistent w ith the 2015 IECC that theyw ould not have otherw ise included, these improvements have already been show n to be cost-effective to the homeow ner by U.S. DOE.


RE158-16 : R406.2-FAY12418

RE158-16R406.2 (IRC N1106.2)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, representing Building Codes Assistance Project ([email protected]); Harry Misuriello,American Council for an Energy-Efficient Economy (ACEEE), representing Energy Efficient Codes Coalition; Jeffrey Harris, Alliance toSave Energy, representing Alliance to Save Energy; William Prindle, ICF International, representing Energy Efficient Codes Coalition


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as â€˜ "mandatoryâ€™ " and Section R40.5.3 R403.5.3 shall be met. The building thermal envelopeshall be greater than or equal to levels comply with section R402.1.5 of efficiency and Solar Heat Gain Coefficient in Table402.1.1 or 402.1.3 of the 2009 International Energy Conservation Codethis code.


Reason: The primary purpose of this code change proposal is to clarify, improve and update the mandatory requirements for the thermal envelope insection R406.2, w hich are currently based on the 2009 IECC prescriptive requirements, to the current code requirements. The proposal w ill ensure areasonable thermal envelope for those w ho use the ERI compliance path, w hile also adding f lexibility by changing the reference for U-factor from theprescriptive component values to the total UA approach under section R402.1.5. This proposal is an alternative to another proposal designed to updatethe values to the current code and otherw ise improve this section. Specif ically, this proposal makes tw o key modif ications to the Energy Rating Index:

The proposal adds f lexibility to the ERI thermal envelope backstop by requiring the building thermal envelope to meet Section R402.1.5, the TotalUA alternative, rather than requiring each component to meet the prescriptive tables of the code. This w ill give builders even more freedom totrade U-factor among thermal envelope components, so long as the total UA is consistent w ith the code UA requirements.The proposal w ill help ensure a more eff icient thermal envelope by updating the referenced code for the thermal envelope backstop from the2009 IECC to the current IECC. At the same time, the reference to a previous code (w hich w as published 9 years earlier) w ill be eliminated,making the backstop requirement fully a part of the current code.

The intent of the IECC (section R101.3) is to "regulate the design and construction of buildings for the effective use and conservation of energy over theuseful life of each building." It is w ell understood that the eff iciency of the permanent thermal envelope is crucial to a home's performance over itsexpected very long useful lifetime. That w as the reason for this backstop to the ERI in the f irst place. This backstop is particularly important given thebroad scope of the ERI, w hich covers all energy use in the home, including appliances, equipment and other features not included in other codecompliance paths. These other measures, many w ith much shorter useful lives, represent a signif icant risk for trade-off against the thermal envelope tothe detriment of long-term energy savings, absent a strong backstop.

Incremental improvements to the thermal envelope are far more cost-effective at construction than they are after the home is built. The purpose of theIECC, like that of all International Codes, is to protect and benefit the ow ners and occupants of buildings. The improvement of the thermal envelopebackstop in the ERI w ill result in less energy usage and low er costs, w hile helping make homes more comfortable, more resilient, and more secureinvestments for homeow ners, and reducing peak demand and equipment sizing. It should be noted that comfortable homes are a key to energyeff iciency, since occupants are likely to modify thermostat settings and use even more energy if uncomfortable due to w eak thermal envelopes.

Cost Impact: Will increase the cost of constructionBecause Section R406.2 serves only as a backstop to ensure a minimum thermal envelope, and the backstop is incorporated into an optional compliancepath (ERI), this proposal does not require the builder to incur additional cost (the builder has the potential to incur additional cost only if the builderselects this compliance path). Moreover, since this section does not require overall eff iciency beyond that w hich is required in Section R406.3, the costimpact even w here this path is used is entirely dependent on design choices made by the builder. For example, if the builder has already met orexceeded the prescriptive thermal envelope requirements of the IECC in achieving the prescribed ERI, as is likely in many cases, then the thermalenvelope backstop in Section R406.2 w ill have no cost impact. By contrast, if the builder w ould have built the thermal envelope to the current minimumbackstop, and offset the difference by improving other components of the building in order to achieve the requisite ERI score, the cost impact w illdepend on w hether the upgrades to non-envelope components cost more or less than the envelope improvements w ould have cost.We note, how ever, that the prescriptive improvements made to the IECC betw een 2009 and 2015 (w hich are the basis for the backstop) have beendemonstrated to be cost-effective to the consumer – irrespective of other trade-offs that may take place. The U.S. DOE found that over a 30-yearuseful lifetime, an ow ner of a home built to the prescriptive and mandatory measures of the 2015 IECC (as compared to the 2009 IECC) could savebetw een $4,418 and $24,003 in energy costs, depending on climate zone. See V. Mendon, et. al., Pacif ic Northw est National Laboratory, National Cost-Effectiveness of the Residential Provisions of the 2015 IECC, at iv (June 2015),https://w w w .energycodes.gov/sites/default/f iles/documents/2015IECC_CE_Residential.pdf. These f igures include the presumed costs of the upgradesover the 2009 IECC. DOE also found that homeow ners w ould achieve a positive cash f low w ithin the f irst tw o years in every climate zone. Id. at v. Theanalysis show s an estimated simple payback period that ranges betw een 2.2 years and 8.1 years, again depending on climate zone. Id.

Thus, if the improved thermal envelope requires builders to incorporate improvements to the thermal envelope consistent w ith the 2015 IECC that theyw ould not have otherw ise included, these improvements have already been show n to be cost-effective to the homeow ner by U.S. DOE.


RE159-16 : R406.2-FAY12419

RE159-16R406.2 (IRC N1106.2)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, representing Building Codes Assistance Project ([email protected]); Harry Misuriello,American Council for an Energy-Efficient Economy (ACEEE), representing Energy Efficient Codes Coalition ([email protected]);Jeffrey Harris, representing Alliance to Save Energy; William Prindle, ICF International, representing Energy Efficient Codes Coalition


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R403.5.3 R403.5.3 be met. The building thermal envelope shall begreater than or equal to levels of efficiency and Solar Heat Gain Coefficient in Table 402.1.1 or 402.1.3 of the 2009 InternationalEnergy Conservation Code. Computer software used to calculate the ERI shall incorporate the requirements of this sectionsuch that the ERI will only be calculated by the software when these requirements are also met. The compliance reportrequired under section R406.6.2 shall list the requirements of this section for each building component and show that they havebeen met.


Reason: The purpose of this code change proposal is to provide additional clarity and direction to softw are makers about how to incorporate themandatory backstop provisions of the Energy Rating Index into compliance softw are programs. Although mandatory provisions and backstops havebeen a part of the International Codes for many years, softw are designed for voluntary or "above-code" programs (such as HERS rating softw are) maynot address mandatory items or treat them w ith the appropriate level of importance. Code off icials understand very w ell that w hen a provision is listedas "mandatory," the building simply cannot achieve compliance w ithout meeting that provision. Now that more and more code users are turning tosoftw are and rating professionals (w ho often use softw are) for code compliance, it is important to provide additional details for softw are developersas to how to incorporate these important provisions.This proposal w ill improve code enforcement by providing a list of applicable mandatory measures and show w hether the requirements have been met.Because the requirements of R406.2 are mandatory, softw are used to calculate the ERI should only produce an ERI for compliance w hen the mandatorycriteria are met. This w ill avoid confusion and increase compliance w ith the mandatory measures.

Cost Impact: Will not increase the cost of constructionThis code change proposal w ill not increase the cost of construction. It clarif ies how compliance softw are developers must incorporate the mandatoryprovisions of the Energy Rating Index into the IECC.


RE160-16 : R406.2-HICKMAN13167

RE160-16IECC: R406.2.Proponent : Amanda Hickman, InterCode Incorporated, representing Leading Builders of America ([email protected])


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R40.5.3 R403.5.3 be met. The building thermal envelope shall begreater than or equal to levels of efficiency and Solar Heat Gain Coefficient comply with the total UA alternative calculated inTable 402.1.1 or 402.1.3 accordance with Section 402.1.4 of the 2009 International Energy Conservation Code.


Reason: This proposal increases f lexibility by giving builders the ability to trade-off building thermal envelope U-factor requirements w hile ensuringoverall energy eff iciency of the building thermal envelope is greater than or equal to the requirements of Table 402.1.3 of the 2009 International EnergyConservation Code. The original language created prescriptive requirements for component R-values or U-factors w ithout the ability to use the total UAalternative compliance path for building thermal envelope eff iciency.

Energy Savings: The proposal is designed to be energy neutral.

Cost Impact: Will not increase the cost of constructionSince trade-offs w ithin Table 402.1.3 of the 2009 International Energy Conservation Code are optional, there is no direct cost impact.

Cost-effectiveness: This change is cost-effective because it is expected to provide neutral or positive energy impact and builders are not required totrade-off building thermal envelope U-factors.


RE161-16 : R406.2-ROSENSTOCK11913

RE161-16R406.2 (IRC N1106.2), R406.3 (IRC N1106.3), R406.5 (IRC N1106.5), R406.6.2 (IRC N1105.6.2),R406.7.1 (IRC N1106.6.2)Proponent : Steven Rosenstock, representing Edison Electric Institute ([email protected])


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the mandatory provisions identified inSections R401 through R404 labeled as "mandatory" R401.2 and Section R40.5.3 the prescriptive provisions of R403.5.3 bemet. The building thermal envelope efficiency shall be greater than or equal to levels of efficiency and Solar Heat GainCoefficient in Table 402.1.1 or 402.1.3 of the 2009 International Energy Conservation Code.


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses consumes no net purchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percentchange in the total energy use of the rated design rated design relative to the total energy use of the ERI reference design. TheERI shall consider all energy used in the residential building.

R406.5 (N1106.5) Verification by approved agency entity. No change to text.

R406.6.2 (N1106.6.2) Compliance report. Compliance software tools shall generate a report that documents that the ERI ofthe rated design complies with Sections R406.3 and R406.4. The compliance documentation shall include the followinginformation:

1. Address or other form of identification of the residential building or buildings.2. An inspection checklist documenting the building component characteristics of the rated design. The inspection


3. Name of individual completing the compliance report.4. Name and version of the compliance software tool used.


R406.7.1 (N1106.7.1) Minimum capabilities. Calculation procedures used to comply with this section shall be software toolscapable of calculating the ERI as described in Section R406.3, and shall include the following capabilities:

1. Computer generation Generation of the ERI reference design using only the input for the rated design.Thecalculation procedure shall not allow the user to directly modify the building component characteristics of the ERIreference design.

2. Calculation of whole building, as a single zone or dual zone, sizing for the heating and cooling equipment in theERI reference design residence in accordance with Section R403.7.

3. Calculations that account for the effects of indoor and outdoor temperatures and part-load ratios efficiency andequipment operation on the performance of heating, ventilating and air-conditioning equipment based on climate andequipment sizing.


Reason: This proposal suggests editorial improvements to this section.For Section 406.2, the proposal makes an editorial correction for Section R.403.5.3, w hich only has prescriptive provisions).

For Section 406.3, the changes are editorial, changing the w ord "uses" to "consumes" and italicizing the phrase "rated design".

For Section 406.5, the editorial change is to account for the fact that an approved third party may not be a government agency.

For Section 406.6.2, there are editorial changes to clarify the section and to account for multiple building projects.

For Section 406.7.1, there are editorial changes for clarif ication and to account for the situations w here homes (larger homes in particular) w ill installdual zone systems in the ERI reference design.

Cost Impact: Will not increase the cost of constructionThis changes are editorial in nature or modify the minimum capabilities of softw are used for simulations, and w ill not have an impact on the cost ofconstruction. They do not make any changes to the energy eff iciency requirements of the section.


RE162-16 : R406.2-SCHWARZ12450

RE162-16R406.2 (IRC N1106.2), R406.4 (IRC N1106.4)Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R406.2 (N1106.2) Mandatory requirements. Compliance with this section requires that the provisions identified in SectionsR401 through R404 labeled as "mandatory" and Section R40.5.3 be met. The building thermal envelope shall be greater than orequal to levels of efficiency and Solar Heat Gain Coefficient in Table 402.1.1 or 402.1.3 of the 2009 International EnergyConservation Code.


R406.4 (N1106.4) ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown tohave an ERI less than or equal to the appropriate value listed in Table R406.4, before solar is added to the calculation, whencompared to the ERI reference design.

Reason: This proposal sets out to accomplish tw o things:

1. Remove the 2009 insulation level back stop to allow greater f lexibility and trade off to seek cost effective means to achieve required codecompliance ERI scores as desired by Builders.

2. Ensure that w ith f lexibility and trade off possibilities that sound building envelopes continue to be maintained by not allow ing solar to drive ahome's ability to meet the required code compliance ERI score. In this w ay the required ERI score itself w ill act as the back stop for thoseconcerned about poor energy performance w hile promoting f lexibility in tradeoffs and cost effective design and implementation.

Cost Impact: Will not increase the cost of constructionThis proposal should allow more f lexibility w hile either not impacting cost or potentially reducing cost by allow ing for more cost effective design andtradeoffs.


RE163-16R406.3 (IRC N1106.3), R406.3.1 (New) [IRC N1106.3.1 (New)], Table R406.3 (New) [IRC TableN1106.3 (New)], R406.3.1 (IRC N1106.3.1), R406.4 (IRC N1106.4), R406.6.2 (IRC N1106.2),R406.6.3 (IRC N1106.3), R406.7 (IRC N1106.7), R406.7.1 (IRC N1106.7.1)Proponent : Ben Edwards, representing self


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses nonet purchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the totalannual energy use cost of the rated design relative to the total annual energy use cost of the ERI reference design. The ERIshall consider all energy used in the residential building.


R406.3.1 (N1106.3) ERI calculation. Equations 4-1, 4-2 and 4-3 shall be used to calculate the ERI for the proposed design:ERI = PEC / REC * 100 (Equation 4-1)

where:

PEC = Total Energy Cost of the proposed design =

Σ(TEU * ECF) (Equation 4-2)REC = Total Energy Cost of the ERI reference design =

Σ(RTEU * ECF) (Equation 4-3)

where:

TEU = Total site energy use for each energy form of the proposed design

RTEU = Total site energy use for each energy form of the reference design

ECF = Energy cost factor for each energy form based on energy prices in the jurisdiction and established by the code official.Such established ECF values shall be inserted into Table R406.3 at the time of adoption by the authority having jurisdiction andshall be updated on a schedule determined by that same authority.

TABLE R406.3 (N1106.3) ENERGY COST FACTORS BY ENERGY FORM

Form of Energy Energy Cost Factor (ECF)

US Dollars Units f or ECF

Electricity [INSERT VALUE] per kWh

Natural Gas [INSERT VALUE] per Therm

Steam [INSERT VALUE] per Million Btu

Hot Water [INSERT VALUE] per Million Btu

Chilled Water [INSERT VALUE] per Million Btu

Fuel Oil [INSERT VALUE] per Gallon

Propane [INSERT VALUE] per Therm

Coal and Other [INSERT VALUE] per Ton

Revise as follows:

R406.3.1 R406.3.2 (N1106.3.2) ERI reference design. The ERI reference design shall be configured such that it meets theminimum requirements of the 2006 International Energy Conservation Code prescriptive requirements for a residentialbuilding with electric heating, cooling, water heating, range, oven, and dryer.



RE163-16 : R406.3-EDWARDS13364

R406.4 (N1106.4) ERI-based compliance. Compliance based on an ERI analysis requires that the rated proposed design beshown to have an ERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERIreferencedesign.

R406.6.2 (N1106.6.2) Compliance report. Compliance software tools shall generate a report that documents that the ERI ofthe rated proposed design complies with Sections R406.3 and R406.4. The compliance documentation shall include thefollowing information:

1. Address or other identification of the residential building.2. An inspection checklist documenting the building component characteristics of the rated proposed design. The

inspection checklist shall show results for both the ERI reference design and the rated proposed design, and shalldocument all inputs entered by the user necessary to reproduce the results.



R406.6.3 (N1106.6.3) Additional documentation. The code official shall be permitted to require the following documents:

1. Documentation of the building component characteristics of the ERI reference design.2. A certification signed by the builder providing the building component characteristics of the rated proposed design.3. Documentation of the actual values used in the software calculations for the rated proposed design.

R406.7 (N1106.7) Calculation software tools. No change to text.


1. Computer generation of the ERI reference design using only the input for the rated proposed design.Thecalculation procedure shall not allow the user to directly modify the building component characteristics of the ERIreference design.



4. Printed code official inspection checklist listing each of the rated proposed design component characteristicsdetermined by the analysis to provide compliance, along with their respective performance ratings.

Reason: This proposed revision focuses on three important changes in the code landscape: energy costs, a single reference building, and existingcode terminology.If approved, the ERI compliance path w ould evaluate energy costs rather than the normalized modif ied end use loads (nMEUL) method currently used inthis section. People understand cost not nMEUL. Consider the difference in explaining $0.13/kWh versus the "b" normalization coeff icient in nMEUL. Costw orks.

Builders, home buyers, mortgage companies, and policymakers responsible for residential building performance decisions understand costs. Otherrating metrics, no matter how w ell intentioned, fail because home-buying and -f inancing decisions are based on costs: mortgage, energy, operation,insurance, etc. This proposal leverages readily available local, state, or national energy costs, as determined by the adopting authority, andrecognizes that building energy conservation decisions are local.

A single reference building is necessary because a f loating baseline perverts decisions, creating w aste as designs adapt to artif icial inequalities.. Themarketplace demands cost optimization, and that can be done only w hen there is a stable benchmark.

Finally, and simply, the terminology has been changed to ref lect that w hich already exists in the code.

Note: No changes are proposed to the eff iciency levels defined by the code, just the means of determining the Energy Rating Index.

Cost Impact: Will not increase the cost of constructionThis proposal does not change the the minimum eff iciency levels defined by the code, and therefore does not affect construction cost. It, how ever,does allow greater design f lexibility by optimizing to cost rather than an abstract end use loads method. Because of the increased f lexibility and thefocus on a cost baseline, this proposal has the potential to reduce construction costs. Builders using this section already w ill have retained a homeenergy rater or other professional engaged in building performance modeling to determine ERI for code compliance. That professional simply w illmultiply the modeled energy use for the proposed design by the local energy costs to determine code compliance. Approved softw are already has theability to automate this step.


RE164-16 : R406.3-FAY12489

RE164-16R406.3 (IRC N1106.3) , R406.4 (IRC N1106.4)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition ([email protected]); Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy;William Prindle, ICF International, representing Energy Efficient Codes Coalition


R406.3 Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on a linear scaleconstructed such that the ERI reference design has an Index value of 100 and a residential building that uses no netpurchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the totalenergy use of the rated design relative to the total energy use of the ERI reference design. The ERI shall consider all energyused in the residential building, and shall not consider or include the effect of any on-site power production.

R406.4 ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown to have anERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERI reference design without anycredit for on-site power production. The report generated by computer software used to calculate the ERI shall demonstrate thatno on-site power production has been incorporated into the ERI calculation.

Reason: The purpose of this code change proposal is to clarify that the Energy Rating Index calculation does not include the impact of on-site pow erproduction, w hether renew able or not. It also provides more specif ic guidance to softw are providers in order to help maintain consistency betw eensoftw are and code compliance on this particular issue.The current plain language of Section R406 does not permit the inclusion of electricity/pow er production in ERI calculations. Consistent w ith the intent ofthe IECC outlined in Section R101.3, to "regulate the design and construction of buildings for the effective use and conservation of energy over theuseful life of each building," the language establishing the ERI in Section R406 properly focuses on energy use and loads, not the production of energy.The methodology prescribed by the ERI provisions does not mention the use of renew able energy or other on-site energy production, and these issuesw ere not reasonably analyzed or addressed during the 2015 IECC code development process.

How ever, some have suggested that because popular home energy rating softw are does include the impact of on-site pow er production in thecalculation of energy ratings, that the ERI should also include on-site pow er production. While in our view , the current code is clear, this code changeproposal w ill address this issue head on and clarify w ith unequivocal language that regardless of the energy rating softw are used, the ERI calculationshall not include renew able or other on-site energy production. It should be noted that current softw are can still be used to calculate the ERI under thisproposal, so long as no on-site pow er production is input into the calculation.

To allow unrestricted trade-offs for on-site pow er production could bring about several negative unintended consequences. The most signif icantproblem w ould be a huge reduction in the eff iciency of the home in favor of on-site pow er production. As an example of the potential impact, a recentreport analyzed the enormous potential impact of solar photovoltaics on the HERS Index. See Residential Energy Services Netw ork, Inc., The Impact ofPhotovoltaic Arrays on the HERS Index (2015), http://w w w .academia.edu/15036659/The_Impact_of_Photovoltaic_Arrays_on_the_HERS_Index. Thisreport found that in most parts of the country, a 4 kW photovoltaic array could reduce a HERS Index Score by 20-40 points. Other analyses have foundeven larger potential reductions in the HERS Index Score. If the IECC w ere amended to allow direct, unlimited trade-offs betw een a photovoltaic systemand the eff iciency of the thermal envelope, it w ould virtually eliminate the need to incorporate eff iciency measures into the home to meet the code,w iping out many years of progress in improving the energy eff iciency of homes. This is fundamentally inconsistent w ith the scope and intent of theIECC, and it should not be permitted.

To be clear, this proposal does not take any position on the value of solar photovoltaics or other types of generation in themselves. In fact, many of theproponents and supporters of this proposal are also strong supporters of renew able energy generation, like solar. We note that sustainability-orientedand green codes such as the IgCC and ICC-700 have addressed on-site pow er production, along w ith other sustainability-oriented measures that arebeyond the scope of an energy conservation code.

How ever, to begin allow ing credit for electric generation to be considered for compliance calculations solely to replace critical energy eff iciencymeasures in the IECC, w ill result in higher peak demands, less occupant comfort and substantial additional energy use given the much longer typical lifeof certain eff iciency measures. Moreover, allow ing credit for generation to be included in residential code compliance w ill substantially complicate thecode and this compliance path. Some of the questions raised by such an approach include: (i) how to address energy sold back to the utility, (ii)treatment of the timing of the electricity production as compared to its use; (iii) w hether there should be a minimum level of generation required; and (iv)how to ensure that the generation is permanent (including issues related to leasing, maintenance, equipment output over time, etc.). Finally, unlikeconservation measures, generation is not integral to the building or its habitability and need not be in the purview of the building code – w hile generationcan be attached to the building or located on the site, there is certainly no requirement that it be, unlike other building components or systems. If electricgeneration is to be included in the IECC – Residential Provisions, it should be included explicitly and in a controlled manner, after a full discussion anddebate. Residential energy code compliance should not be extended to cover electric generation through the backdoor of the ERI.

For all these reasons, w e recommend that the IECC be clarif ied to specif ically exclude on-site pow er production from the ERI calculation.

Cost Impact: Will not increase the cost of constructionThis code change proposal w ill not increase the cost of construction. It is simply a clarif ication of language in Section R406 that already does not permiton-site pow er production to be included in the Energy Rating Index calculation.


RE165-16R406.3 (IRC N1106.3), R406.3.1 (IRC N1106.3.1), R406.4 (IRC N1106.4), R406.4.1 (New) [IRCN1106.1 (New)], Table R406.4.1 (New) [IRC Table N1106.1 (New)], R406.6, R406.6.1 (IRCN1106.6.1), R406.6.2 (IRC N1106.6.2), R406.7 (IRC N1106.7), R406.7.1 (IRC N1106.7.1), R406.7.2(IRC N1106.7.2), R406.7.3 (IRC N1106.7.3)Proponent : Vickie Lovell, InterCode Incorporated, representing Leading Builders of America ([email protected])


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 determined in accordance withANSI/RESNET/ICC 301-2014, Republished January 2016, Addendum A-2015 and a residential building that uses no netpurchased energy has an Index value of 0 Addendum B-2015. Each integer value on the scale shall represent a 1-percentchange in the total energy use of the rated design relative to the total energy use of the ERI reference design. The ERI shallconsider all energy used in the residential building.


R406.3.1(N1106.3.1) ERI reference design. The ERI reference design shall be configured such that it meets the minimumrequirements of the 2006 International Energy Conservation Code prescriptive requirements.


Revise as follows:

R406.4 (N1106.4) ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown tohave an ERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERIreference design.



1 52

2 52

3 51

4 54

5 55

6 54

7 53

8 53


R406.4.1 (N1106.4.1) On-site power production. Where on-site power is provided, the contribution of power produced on-siteto the ERI shall not exceed the percentages specified in Table R406.4.1


TABLE R406.4.1 (N1106.4.1) Credit for On-site Power Production

ENERGY RATING INDEX

(ERI) OF RATED DESIGN

% CREDIT FOR ON-SITE

POWER PRODUCTIONa

65 and abov e 0

64 5

63 10


62 15

61 20

60 25

59 30

58 35

57 40

56 45

55 50

54 55

53 60

52 65

51 70

50 75

49 80

48 85

47 90

46 95

45 and below 100

a. Percentage of power produced on-site applied per ERI value.

R406.5 (N1106.5) Verification by approved agency. No change to text.

Revise as follows:

R406.6 (N1106.6) Documentation. Documentation of the software used to determine the ERI and the parameters for theresidential building shall be in accordance with Sections R406.6.1 through R406.6.3 R406.6.5.

R406.6.1 (N1106.6.1) Compliance software tools. Documentation verifying thatSoftware tools used for determining the methods and accuracy of the compliance software tools conform to the provisions ofthis section ERI shall be provided to the code officialApproved Software Rating Tools in accordance with ANSI/RESNET/ICC301-2014 Republished January 2016, Addendum A-2015 and Addendum B-2015.

R406.6.2 (N1106..6.2) Compliance report. Compliance software tools shall generate a report that documents that the ERI ofthe rated design complies with Sections R406.3 and R406.4. The compliance documentation shall include the followinginformation:


checklist shall show results for both the ERI reference design and the rated design, and shall document all inputsincluding the percentage of power produced on-site credited to the ERI entered by the user necessary to reproducethe results.






R406.7.2 R406.6.4 (N1106.6.4) Specific approval. Performance analysis tools meeting the applicable sections of SectionR406 shall be approved. Tools are permitted Documentation demonstrating the approval of performance analysis tools inaccordance with Section R406.6.1 shall be provided to be theapproved code official based on meeting a specified threshold fora jurisdiction. The code official shall approve tools for a specified application or limited scope.

R406.7.3 R406.6.5 (N1106.6.5) Input values. When calculations require input values not specified by Sections R402, R403,R404 and R405, those input values shall be taken from an approved source ANSI/RESNET/ICC 301-2014.


R406.7 (N1106.7) Calculation software tools. Calculation software, where used, shall be in accordance with SectionsR406.7.1 through R406.7.3.

R406.7.1 (N1106.7.1) Minimum capabilities. Calculation procedures used to comply with this section shall be softwaretools capable of calculating the ERI as described in Section R406.3, and shall include the following capabilities:





This code change proposal for the indicated sections of the IECC-Residential Provisions is also intended for the correspondingsections of Chapter 11 of the IRC.Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ANSI/RESNET/ICC 301-2014 Standard for the Calculation and Labeling of the Energy Performance of Low-Rise ResidentialBuildings using an Energy Rating IndexFirst Published March 7, 2014 Republished January 2016, Addendum A-2015 and Addendum B-2015.Reason: This proposal creates an easy to enforce method that recognizes on-site pow er production, but LIMITS THE CREDIT FOR POWER PRODUCEDON-SITE THAT MAY BE APPLIED TO THE CALCULATION OF THE ERI.The CONCEPT –The International Code Conservation Code should not be inconsistent w ith the federal policy (and many state statutes) that encourage national energyindependence through conservation, and incentivizes the use of on-site pow er generation in residential buildings. This proposal creates a compliancemethod that is easy to enforce and a design tool that is easy to use and understand.

A method for calculating for on-site pow er in the ERI is not currently required anyw here in Section 406. This proposal does NOT require on-site pow erproduction to be calculated in the ERI. It only limits how much on-site pow er is allow ed to be considered in calculating the ERI if and w hen the designerchooses to incorporate on-site pow er in the total energy use of the rated design.

The new Table 406.6.1 promotes both energy conservation and energy production. It accomplishes this by driving improvements in the buildingenclosure and installed mechanical systems in order to earn greater contributions from the production of on-site pow er w hile maintaining the protectionsof meeting the code envelope requirements and mandatory measures in the 2009 IECC.

Homes currently have to meet the mandatory building requirements of the 2009 IECC. That does not change w ith the implementation of the new Table406.4.1. Compliance w ith the 2009 "backstop" provisions ensure that the building itself is eff icient.

The METHOD –

The proposed new Table 406.4.1 starts crediting on-site pow er at an ERI of 64 and moves in 5% increments per integer until 100% of on-site pow erproduced may be applied to the ERI. The percentages in Table 406.4.1 represent those 5% increments.

The value of 65 for w as selected for the Table 406.4.1 because it is the AVERAGE HERS RATING of over 610,000 new homes built since 2012 asreported by RESNET.

The designer can adjust the rated design by calculating exactly w hat percentage of the on site pow er may be utilized in the rated design to achieve acode compliant ERI scores found in Table 406.4

The new Table 406.4.1 is also designed to account for ERI scores that states and local jurisdiction may adopt that are both above and below the ERIvalues currently listed on Table R406.4. Table 406.4 is adaptable to states and local jurisdictions that are adopting different ERI scores different fromw hat is contained in the 2015 IECC, such as Texas that adopted an ERI score of 65. The values in Table R406.4.1 can be applied to these higher ERIscores w hich w ould limit on-site pow er production consistently from state to state regardless of the ERI adopted by the states. The low er values (morestringent) than the current Table R406.4 values also "future proof" the table to account for more stringent ERI scores in later versions of the IECC.

The ENFORCEMENT –

Compliance w ith Table 406.4.1 is easy. The code off icial or plan review er only has to review the compliance report for the ERI score that is required forthe climate zone in Table 406.4. The code off icial or plan review er then needs to verify that that the percentage of on-site pow er cited in the compliancereport is consistent w ith percentage listed in Table 406.4.1.There is a companion proposal to this change to require that the percentage of onsite pow erused in the ERI in found in the compliance report.

The CONCLUSION

Enabling new paths to achieve energy eff iciency creates new opportunities for even greater innovation is part of the stated purpose of the IECC. Thisis yet another option, the most stringent yet f lexible of all the compliance options w ithin the IECC, for consumers and builders. Pow er produced on-site isgaining steadily in popularity w ith homeow ners and can help reduce the compliance costs for builders, making homes more affordable to build and tolive in.


RE165-16 : R406.3-LOVELL13344

Cost Impact: Will not increase the cost of constructionBecause on-site pow er production is not required to achieve code compliant Energy Rating Index values and this proposal only limits the amount of on-site pow er produced that can be applied to reduce the ERI to achieve code compliance, there is no direct cost impact.

Cost-effectiveness: This change is cost-effective because it is expected to provide neutral or positive energy impact and builders are not required touse on-site pow er production to reach code compliant Energy Rating Index values

Analysis: A review of the standard(s) proposed for inclusion in the code, ANSI/RESNET/ICC 301-2014 (Republished January 2016) , w ith regard to theICC criteria for referenced standards (Section 3.6 of CP#28) w ill be posted on the ICC w ebsite on or before April 1, 2016.


RE166-16R406.3 (IRC N1106.3), R406.3.1 (IRC N1106.3.1), R406.6.1 (IRC N1106.6.1), R406.7 (IRCN1106.7), R406.7.1 (IRC N1106.7.1), R406.7.2 (IRC N1106.7.2), R406.7.3 (IRC N1106.7.3)Proponent : Eric Makela, Cadmus Group, representing RESNET


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses nonet purchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change determinedin the total energy use of the rated design relative to the total energy use of the ERI reference designaccordance withANSI/RESNET/ICC 301. The ERI shall consider all energy used in the residential building.


R406.3.1 (N1106.3.1) ERI reference design. The ERI reference design shall be configured such that it meets the minimumrequirements of the 2006 International Energy Conservation Code prescriptive requirements.


Revise as follows:

R406.6.1 (N1106.6.1) Compliance software tools. Documentation verifying thatSoftware tools used for determining the methods and accuracy of the compliance software tools conform to the provisions ofthis section ERI shall be provided to the code officialApproved Software Rating Tools in accordance with ANSI/RESNET/ICC301.

R406.7.2 R406.6.4 (N1106.6.4) Specific approval. Performance analysis tools meeting the applicable sections of SectionR406 shall be approved. Tools are permitted Documentation demonstrating the approval of performance analysis tools inaccordance with Section R406.6.1 shall be provided to be approved based on meeting a specified threshold for a jurisdiction the code official. The code official shall approve tools for a specified application or limited scope.

R406.7.3 R406.6.5 (N1106.6.5) Input values. When calculations require input values not specified by Sections R402, R403,R404 and R405, those input values shall be taken from an approved source ANSI/RESNET/ICC 301.


R406.7 (N1106.7) Calculation software tools. Calculation software, where used, shall be in accordance with SectionsR406.7.1 through R406.7.3.

R406.7.1 (N1106.7.1) Minimum capabilities. Calculation procedures used to comply with this section shall be softwaretools capable of calculating the ERI as described in Section R406.3, and shall include the following capabilities:





Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ANSI/RESNET/ICC 301-2014 Standard for the Calculation and Labeling of the Energy Performance of Low-Rise ResidentialBuildings using an Energy Rating Index First Published March 7, 2014 Republished January 2016

Reason: During the 2015 code development cycle, a collaborative code change proposal (RE188-13) to include the ERI approach in the code w assubmitted by the Institute for Market Transformation, Natural Resources Defense Council and Britt/Makela Group. The ERI approach w as adopted in thecode as Section R406 and is currently being adopted by states and local jurisdictions.The collaborative team based the ERI code language on the yet to be approved standard ANSI/RESNET/ICC-301. This required the team to includelanguage from the standard concerning the development of the Energy Rating Index (see Section R406.3), compliance softw are tool approval(R406.6.1) and the minimum capabilities of the softw are used to determine an ERI for a project (R406.7.1). Overall the language that w as included in theproposal provides the basic concepts for developing a program to meet the ERI approach but referencing the RESNET/ICC-301 w ould ensure that theERI approach is deployed using a standardized process from a consensus document.

This proposal references RESNET/ICC – 301 RESNET/ICC – 301 and strikes all language in C406 that is duplicated in the Standard or that is no longerneeded in the code because the concept is covered in the Standard.

RESNET/ICC - 301 Standard for the Calculation and Labeling of the Energy Performance of Low -Rise Residential Buildings using an Energy Rating Indexprovides a consistent, uniform methodology for evaluating and labeling the energy performance of residences. The methodology compares the energy


RE166-16 : R406.3-MAKELA12647

performance of an actual home w ith the energy performance of a reference home of the same geometry, resulting in a relative energy rating called theEnergy Rating Index. Where the energy performance of the actual home and the reference home are equal, the Energy Rating Index is 100 and w herethe actual home requires no net purchased energy annually, the Energy Rating Index is 0 (zero). Per the provisions of R406, the Energy RatingReference Home used for this comparative analysis has the energy attributes of the 2006 International Energy Conservation Code (IECC) StandardReference Design. Thus, the Energy Rating Index is relative to the minimum building energy eff iciency requirements of the 2006 IECC.

Cost Impact: Will not increase the cost of constructionAs stated in the Reason Statement, the ERI approach submitted during the 2015 IECC code development cycle (RE188-13) w as based on the yet to beapproved Standard 301. The ERI values that populate Table R406.4 w ere calculated and based on the protocol described in Standard 301 soreferencing this standard w ill not lead to an increase in the stringency of the ERI values and w ill not result in an increase in f irst cost for the construction of the house. This proposal DOES NOT propose to change the Section R406.2 requiremets for Mandatory Requirements or the 2009 IECCas minimum requirement w hich w ould increase f irst cost. The Energy Rating Index described in Section R406.3 is consistent w ith Standard 301. Therequirements for Calculation Softw are Tools in Section R406.7 w ill not increase the cost to develop softw are as the requirements are consistent w iththe requirements in Standard 301. Standard 301 does not place additional requirements into C406 but provides a stadardized method for generating ERIscores and demonstrating compliance w ith the R406.



RE167-16R406.3 (IRC N1106.3), R406.3.1 (IRC N1106.3.1), Table R406.3.1 (New) [IRC Table N1106.3.1(New)], R406.4 (IRC N1106.4), R406.6.2 (IRC N1106.6.2), R406.6.3 (IRC N1106.6.3), R406.7.1 (IRCN1106.7.1)Proponent : Chris Mathis, Mathis Consulting Company ([email protected])


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses nonet purchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the totalprimary energy use of the rated designproposed design relative to the total primary energy use of the ERI reference design. TheERI shall consider all energy used in the residential building.


R406.3.1 (N1106.3.1) ERI Calculations Equations 4-1, 4-2 and 4-3 shall be used to calculate the ERI for the proposed design.

ERI = PEC / RPEC * 100 (Equation 4-1)

where:

PEC = Total Primary Energy Consumption of the proposed design = Σ(TEUef * PEFef) (Equation 4-2)

RPEC = Total Primary Energy Consumption of the ERI reference design = Σ(RTEUef * PEFef) (Equation 4-3)

and where:

TEUef = Total site energy use for the proposed design

RTEUef = Total site energy use for the reference design

PEFef = Primary energy conversion factor for each energy form as indicated in Table R406.3.1.

TABLE R406.3.1 (N1106.3.1) PRIMARY ENERGY FACTORS BY ENERGY FORM

Energy Form Primary Energy Factor (PEFef )

Imported Electricity 3.15

Imported Natural Gas 1.09

Imported Steam 1.45

Imported Hot Water 1.35

Imported Chilled Water 1.04

Imported Fuel Oil 1.19

Imported Propane 1.15

Imported Coal and Other 1.05

Exported Electricity 3.15

Exported Steam 1.45

Exported Hot Water 1.35

Exported Chilled Water 1.04


Revise as follows:

R406.3.1 R406.3.2 (N1106.3.2) ERI reference design. The ERI reference design shall be configured such that it meets theminimum requirements of the 2006 International Energy Conservation Code prescriptive requirements for a residential buildingwith electric heating, cooling, water heating, range oven, and dryer.


R406.4 (N1106.4) ERI-based compliance. Compliance based on an ERI analysis requires that the rated proposed design beshown to have an ERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERIreferencedesign.

R406.6.2 (N1106.6.2) Compliance report. Compliance software tools shall generate a report that documents that the ERI ofthe rated proposed design complies with Sections R406.3 and R406.4. The compliance documentation shall include thefollowing information:

1. Address or other identification of the residential building.2. An inspection checklist documenting the building component characteristics of the rated proposed design. The

inspection checklist shall show results for both the ERI reference design and the rated proposed design, and shalldocument all inputs entered by the user necessary to reproduce the results.




1. Documentation of the building component characteristics of the ERI reference design.2. A certification signed by the builder providing the building component characteristics of the rated proposed design.3. Documentation of the actual values used in the software calculations for the rated proposed design.


1. Computer generation of the ERI reference design using only the input for the rated proposed design.Thecalculation procedure shall not allow the user to directly modify the building component characteristics of the ERIreference design.



4. Printed code official inspection checklist listing each of the rated proposed design component characteristicsdetermined by the analysis to provide compliance, along with their respective performance ratings.

Reason: This proposed revision focuses on three important changes to the code:

1. Shifting ERI-based compliance to PRIMARY ENERGY CONSUMPTION [rather than the "normalized modif ied end use loads (nMEUL)" – currentlyreferenced in the code and used only in RESNET Standard 301 and therefore problematic w ith respect to proprietary exclusion w ithin the code].PRIMARY ENERGY CONSUMPTION is a w ell understood and proven technique used by ASHRAE and others, provides equitable treatment of alltechnologies based on their impact on primary energy resources rather than on nMEUL, and prevents gaming of the ERI compliance approachas currently exists. The use of PRIMARY ENERGY CONSUMPTION also allow s for easy conversion of ERI-based compliance values to carbonequivalent metrics, for w hich there is grow ing demand in the residential market.

2. Establishing a SINGLE BASELINE home as the reference design. The 2006 IECC-compliant reference design home is set to be an all-electric onefor consistent comparison w hen using the ERI compliance path. This prohibits gaming of ERI-based compliance by establishing a single baselineagainst w hich all ERI values are calculated.

3. Changing "rated design" to "proposed design" in this section, opting to utilize an already code-defined term. "Proposed design" has long beenused in the code for performance-based compliance calculations. It is also the appropriate term for performance–based compliance using theERI methodology.

Additional justification – Objective 1:The nMEUL methodology currently in Section 406 creates (unintended) biases that unfortunately result in favoring one energy form over another. Forexample, homes using NAECA minimum eff iciency electric resistance storage w ater heating receive an identical HERS score and ERI value as a NAECAminimum gas storage w ater heater, even though both the annual energy costs and primary energy consumption are higher for the resistance w aterheater than for the gas w ater heater (typically tw ice as high). This bias in nMEUL results in HERS ratings and ERI values that favor ultra-high eff iciencygas technologies (such as gas heat pumps) and low -eff iciency electric technologies. This proposal fully eliminates this fundamental technical f law inERI-based compliance currently in Section 406.

Site energy measurement — a calculation of the energy consumed by an appliance at the end-use point — neither accounts for combined fuel use (ex.,electric component of furnaces or combined heat and pow er) nor the substantial energy lost and emissions created throughout the extraction,processing, transportation, conversion, and distribution components of energy use. Alternatively, PRIMARY ENERGY CONSUMPTION – by definition –does account for the energy losses that occur in the production and delivery of the many types of energy that may be used in residential buildings.

The energy meter(s) on a home is only the end of a long series of energy transformations and movements. To ignore the original source of the energyimplies that energy appears as if by magic at the meter, and upstream energy losses are not relevant to the building. Using that argument, 1 Btu ofelectricity w ould be considered the same as 1 Btu of natural gas, propane, or fuel oil. This w ould be f ine if each form of energy w ere equivalent. Theyare not. For example, the versatility of electricity – easily converted to light, heat, motion, etc. – is w hy users pay a premium for it over other forms (ex.,w ood, gas, oil).

Focusing on site energy eff iciency alone promotes irrational design decisions. Codes, standards, regulations, voluntary initiatives, and incentive


RE167-16 : R406.3-MATHIS13264

programs using site energy metrics create and maintain a perverse market advantage to a selection of technologies (ex., electric resistance heating)that have low er initial cost, but that have higher operating cost, low er full-fuel-cycle eff iciency, and higher GHG emissions. This is a key reason sourceenergy-based criteria are used by several private and public sector stakeholders, including RESNET (see referenced links below ).

This proposal's primary energy performance methodology provides equitable treatment of ALL energy consuming technologies based on their primaryenergy impact, not their site energy impact (nor normalized modif ied site energy load impact). It does not prohibit any technology, but equitably rew ardsand penalizes technologies in the home rating based on their PRIMARY ENERGY performance. It uses single national primary energy conversion factorsto avoid rew arding or penalizing a home simply based on its location (similar to the Section R405 performance option).

The primary energy conversion factors in proposed Table 406.3 are from Table J.1 of ANSI/ASHRAE Standard 105.

Primary energy methodologies are implemented easily and now are recognized and used in the United States and internationally. The follow ing listillustrates the numerous domestic and international codes, standards, and initiatives that are successfully incorporating primary energy methodologies:

1. DOE Home Energy Score Tool, 2010. US Department of Energy. 2. 2012 California Green Building Standards Code (CALGreen), 2012.3. LEED Programs. 2012. US Green Building Council.4. International Green Construction Code. 2015. International Code Council.5. EPA Energy Star Buildings and Plants rating and labeling program (including Portfolio Manager and Target Finder). 2012. EPA.6. ASHRAE Building Energy Quotient Labeling Program (As Designed, and In Operation). 2012. ASHRAE. 7. DOE Commercial Building Asset Rating Program. 2012. US Department of Energy. 8. Green Globes for Commercial Buildings. 2012. Green Building Initiative.9. PlaNYC's Greener, Greater Buildings Plan (annual benchmarking and disclosure of energy usage). 2012.

10. Standard Methods of Determining, Expressing and Comparing Building Energy Performance and Greenhouse Gas Emissions. ANSI/ASHRAEStandard 105-2014

11. Benchmarking of Federal Facilities Building Energy Use Benchmarking Guidance. 2010. EISA Section 432. US Dept of Energy/Energy Eff iciency& Renew able Energy (EERE).

12. National Academy of Sciences Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building ApplianceEnergy-Eff iciency Standards. 2009.

13. DOE Policy to use full-fuel-cycle measures of energy use and greenhouse gas and other emissions in the national impact analyses andenvironmental assessments included in rulemakings for future energy conservation standards.

14. The Greenhouse Gases, Regulated Emissions and Energy Use in Transportation Model. 2015. Argonne National Laboratory.15. Source Energy and Emission Factors for Energy Use in Buildings. 2007. National Renew able Energy Laboratory, Authors M. Deru and P.

Torcellini. 16. Providing Credit Tow ard Energy Eff iciency Goals for Cost-Effective Projects Where Source Energy Use Declines But Site Energy Use

Increases. Section 502(e) Guidance. 2004. US Department of Energy/Energy Eff iciency & Renew able Energy (EERE). 17. European Standard EN 15603 Energy performance of buildings. Overall energy use and definition of energy ratings. 2008. European Committee

for Standardization. 18. European Standard EN 15217 Energy Performance of Buildings – Methods for Expressing Energy Performance and for Energy Certif ication of

Buildings. 2007. European Committee for Standardization.

All of these codes, standards, rating programs, and policies acknow ledge the limitations and deficiencies of site energy-based metrics inachieving their energy eff iciency and GHG emission reduction objectives, and have selected primary energy eff iciency metrics and related GHGemission calculations as the technical basis of compliance requirements or analysis methodology. These voluntary and regulatory initiativesillustrate the strong technical justif ication and support for the use of PRIMARY ENERGY as the basis of the ERI compliance path in place of theflaw ed nMEUL approach.

Additional Justification – Objective 2:This revision also specif ies a single electric reference design for heating, cooling, w ater heating, range, oven, and dryer systems in R406.3.2.

A single baseline reference design provides an equitable credit or penalty to all technologies irrespective of energy form or technology design. Itestablishes f ixed reference home performance requirements BEFORE making the technology and energy choices for the residential building. It is criticalfor equitable implementation of ERI compliance requirements. A single reference design methodology creates a level playing f ield for all technology andenergy forms and provides equitable treatment of advanced renew able, w aste heat recovery, hybrid, and multi-fuel technology options. It is especiallyimportant for equitable and consistent evaluation of on-site pow er generation and combined heat and pow er systems.

This revision is consistent w ith the single reference building methodology in the performance path in IgCC; ASHRAE Standards 90.1, 100, and 189.1;ASHRAE's bEQ program; EUI calculations from the EPA in the Energy Star Buildings program; and the DOE Home Energy Score Tool. Each of thesemethodologies establishes a single reference building as the basis of their energy rating and eff iciency compliance requirements. A consistent singlestandard reference design methodology w ill improve the adoptability of the ERI compliance path by ensuring transparency and equity for all technologiesand eliminating confusion at jurisdictional levels.

Cost Impact: Will not increase the cost of constructionThis proposal does not change the minimum compliance requirements. The proposal does change the methodology used to determine the Energy RatingIndex. This methodology provides greater design f lexibility due to primary energy benefits not captured in the current normalized modif ied end use loadsmethod and thus does not affect the cost of construction.


RE168-16R406.3.1(IRC N1106.3.1), R406.4(IRC N1106.4), Table R406.4.1 (New) [IRC Table N1106.4.1 (New)],R406.6(IRC N1106.6), R406.6.1(IRC N1106.6.1), R406.7(IRC N1106.7), R406.7.1 (IRC N1106.7.1)R406.7.2(IRC N1106.7.2), R406.7.3(IRC N1106.7.3)Proponent : Lauren Urbanek, Natural Resources Defense Council, representing NRDC ([email protected])


R406.3 (N1106.3) Energy Rating Index. The Energy Rating Index (ERI) shall be a numerical integer value that is based on alinear scale constructed such that the ERI reference design has an Index value of 100 and a residential building that uses nonet purchased energy has an Index value of 0. Each integer value on the scale shall represent a 1-percent change in the totalenergy use of the rated design relative to the total energy use of the ERI reference designaccordance with RESNET/ICC 301.The ERI shall consider all energy used in the residential building.

R406.3.1 (N1106.3.1) ERI reference design. The ERI reference design shall be configured such that it meets in accordancewith the minimum requirements of the 2006 International Energy Conservation Code prescriptive requirements HERS ReferenceHome as described in RESNET/ICC 301.


R406.4.1 Renewable energy systems. The use of renewable energy systems is permitted to be considered in meeting thevalues listed in Table R406.4 only if the ERI for the proposed residential building without renewable energy systems is less thanor equal to the appropriate value listed in Table R406.4.1.

TABLE R406.4.1 Maximum Energy Rating Index

Climate Zone Energy Rating Index

1 57

2 57

3 57

4 61

5 61

6 61

7 58

8 58

R406.6 Documentation. Documentation of the software used to determine the ERI and the parameters for the residentialbuilding shall be in accordance with Sections R406.6.1 through R406.6.3 R406.6.5.

R406.6.1 Compliance software tools. Documentation verifying thatSoftware tools used for determining the methods and accuracy of the compliance software tools conform to the provisions ofthis section ERI shall be provided to the code officialApproved Software Rating Tools in accordance with RESNET/ICC 301.

R406.7.2 R406.6.4 Specific approval. Performance analysis tools meeting the applicable sections of Section R406 shall beapproved. Tools are permitted Documentation demonstrating the approval of performance analysis tools in accordance withSection R406.6.1 shall be provided to be theapproved code official. based on meeting a specified threshold for a jurisdiction.The code official shall approve tools for a specified application or limited scope.

R406.7.3 R406.6.5 Input values. When calculations require input values not specified by Sections R402, R403, R404 andR405, those input values shall be taken from an approved source RESNET/ICC 301.


R406.7 Calculation software tools. Calculation software, where used, shall be in accordance with Sections R406.7.1through R406.7.3.

R406.7.1 Minimum capabilities. Calculation procedures used to comply with this section shall be software tools capable ofcalculating the ERI as described in Section R406.3, and shall include the following capabilities:

1. Computer generation of the ERI reference design using only the input for the rated design.The calculation


procedure shall not allow the user to directly modify the building component characteristics of the ERI referencedesign.




Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ANSI/RESNET/ICC 301-2014: Standard for the Calculation and Labeling of the Energy Performance of Low-Rise ResidentialBuildings using an Energy Rating Index First Published March 7, 2014 Republished January 2016Reason: The purpose of this proposal is tw o-fold: (a) to formally link the definition of the Energy Rating Index (ERI) to the ANSI/RESNET/ICC 301-2014standard and (b) create a reasonable pathw ay to allow a limited amount of credit for on-site renew able energy in the 2018 code.

(a) The ERI compliance alternative adopted in the 2015 code outlines a framew ork for a builder to comply w ith the code via a generically-designedenergy rating index. While the HERS score, as defined in ANSI/RESNET/ICC 301-2014, is the industry standard and the most commonly used method tocomply w ith the ERI compliance alternative, the 2015 code does not explicitly reference the ANSI/RESNET/ICC 301-2014 standard. The HERS score iscurrently recognized as one possible ERI method, not the exclusive ERI method. This proposal formalizes that relationship by defining the ERI score asdetermined by the ANSI/RESNET/ICC 301-2014 standard.

As w ritten, the 2015 code allow s for the possibility that an entity may invent an alternative energy rating index system that complies w ith the letter ofSection R406, but results in dramatically dif ferent energy consumption of a home built to this compliance alternative. Explicitly referencingANSI/RESNET/ICC 301-2014 closes this potential loophole and ensures that all homes built in compliance w ith Section R406 meet the same standard. The rest of the IECC references established standards to ensure that the code is as unambiguous as possible. Explicitly referencing ANSI/RESNET/ICC301-2014 makes Section R406 structurally consistent w ith the rest of the code.

The 2015 code is ambiguous about w hether or not renew able energy systems are permitted to count tow ard the ERI value. The current languagespecif ies that the proposed residential building shall be show n to have an annual total normalized modif ied load less than or equal to the annual totalloads of the ERI reference design. The presence of a renew able energy system w ill not affect the building's total load. How ever, the code also refers toa scenario w here a residential building that uses zero net purchased energy w ould have an Index value of zero. This creates an internal contradictionw ithin the existing code language that is currently left open for interpretation by individual jurisdictions, creating uncertainty for builders and consumers.This ambiguity w ill be resolved by referring to the ANSI/RESNET/ICC 301-2014 standard.

(b) Referencing the ANSI/RESNET/ICC 301-2014 resolves the ambiguity of w hether or not renew able energy systems are permitted to count tow ard theERI value, but creates an additional issue w hich must be resolved. The HERS rating system outlined in ANSI/RESNET/ICC 301-2014 allow s a home tohave unlimited renew able energy: a home can have a HERS score of zero, w hich necessitates a signif icant contribution of renew able generation. Thisis the right approach for a rating system, but is not the right approach for a code. While a rating system encourages competition among home buildersand can be used effectively to assess both new and existing homes, the purpose of a conservation code is to conserve energy by increasing a home'senergy eff iciency.

The ERI levels set in the 2015 code w ere set based on calculations of cost-effective energy eff iciency levels, including trade-offs made against variousbuilding envelope options. The analysis during the development of the 2015 ERI levels did not account for the impact of renew able energy generation. Amedium-sized solar installation is w orth approximately 35 points. If unlimited renew able generation w as allow ed to count tow ard the ERI score, there isthe potential for a substantial portion of the ERI score to be met w ith renew able systems, resulting in homes that are even less eff icient than the 2009code. Allow ing unlimited renew able generation w ould mean that homes could be built w ith few er eff iciency measures, w hich w ould move thestringency of the conservation code backw ard. It is NRDC's view that the code should be made more stringent w ith subsequent iterations, as long asthere are cost-effective improvements to be had.

Builders may have additional incentive to prioritize PV over eff iciency. Given the innovative f inancing options available, builders may be able to w orkw ith solar companies to install PV at no cost of materials or construction. In this situation, the homeow ner then enters into a pow er purchase agreementdirectly w ith the solar provider. If solar is allow ed as a substitute for eff iciency, the baseline home w ill use more energy, the solar system w ill need tobe larger (and therefore more expensive), and the home w ill be more vulnerable to higher bills if and w hen the solar system is removed. None of theseissues factor into the builder's decision-making, but they directly affect the homeowner over the lifetime of the home. The code is in place to ensure thathome buyers receive a high-quality product that is relatively standardized, no matter w here or by w hom the home is built. Allow ing unlimited renew ablecredit to take the place of eff iciency measures in the code adds uncertainty for the home buyer.

In addition to the energy conservation intent of the code, homeow ners benefit from a more eff icient home even if much of their load is offset by PV oranother renew able source. Energy eff iciency upgrades promoted in the code, like insulation and air sealing, are essentially permanent and diff icult toremove. While the lifespan of solar panels is improving, the output of the panels decreases over time. A homeow ner w ill eventually need to replace thepanels, w hich w ill come at an added expense. Furthermore, the homeow ner could choose to remove the panels at virtually any time. If a home isdesigned to be built less-eff iciently, w ith solar panels making up the difference, then the homeow ner is left w ith a baseline home that w ill consume moreenergy over its lifespan.

NRDC proposes allow ing renew able energy to contribute to the ERI score, but only if the home w ithout renew able energy meets a certain thresholdvalue, ref lected in Table R406.4.1.

Cost Impact: Will not increase the cost of constructionThis proposal offers clarif ication of code language by linking the ERI compliance option to the RESNET standard and specifying how to account forrenew able energy. The proposal only affects homes installing solar panels and using the ERI compliance path, w hich is only one compliance optionavailable to builders. The code requirements are not proposed to be changed, rather clarif ied for builders choosing this very specif ic scenario. This


RE168-16 : R406.3-URBANEK12997

proposal does not affect the cost of construction available to the builder under other compliance options.

Analysis: A review of the standard(s) proposed for inclusion in the code, ANSI/RESNET/ICC 301-2014(Republished January 2016), with regard to the ICC criteria forreferenced standards (Section 3.6 of CP#28) will be posted on the ICC website on or before April 1, 2016.


RE169-16 : R406.3.1-COLLINS11669

RE169-16R406.3.1 (IRC: N1106.3.1)Proponent : David Collins, representing Sustainability, Energy, High Performance Code Action Committee




Energy used to recharge or refuel a a vehicle for on road transportation use off site of the building shall not be included in thereference design or the rated design.

Reason: With the grow th of electric pow ered and rechargeable hybrid vehicles, more and more residential buildings have recharging stations built intothe structure. While the energy is transfer to the vehicle at the building, it is not energy used by the building, but rather by vehicles w hich are used off-site. While it is recognized that there is a broader goal to reduce energy use and the use of fossil fuels, the focus of the IECC is reduction of use inbuildings. The energy transferred to vehicles should not be part of the equations.

This proposal w as submitted by the ICC Sustainability Energy and High Performance Code Action Committee (SEHPCAC). The SEHPCAC w asestablished by the ICC Board of Directors to pursue opportunities to improve and enhance International Codes w ith regard to sustainability, energy andhigh performance as it relates to the built environment included, but not limited to, how these criteria relate to the International Green Construction Code(IgCC) and the International Energy Conservation Code (IECC). In 2015, the SEHPCAC has held three tw o- or three-day open meetings and 25w orkgroup calls, w hich included members of the SEHPCAC as w ell as any interested parties, to discuss and debate proposed changes and publiccomments. Related documentation and reports are posted on the SEHPCAC w ebsite at: http://w w w .iccsafe.org/cs/SEHPCAC/Pages/default.aspx

Cost Impact: Will not increase the cost of constructionThe intent of the section is to properly analyze the use of energy by the building. As the proposal eliminates from the equations, energy w hich isessentially used off-site, the building features w ill not have to compensate to achieve the same rating for the building. Thus, the building w ill cost thesame or possibly less than before.



RE170-16R406.3.1 (IRC N1106.3.1)Proponent : Craig Conner, representing self ([email protected]); Kendra Cardinale, representing Building Quality



The proposed residential buildingresidential building shall be shown to have an annual total normalized modified load energycost less than or equal to the annual total loads energy cost of the ERI reference designERI reference design based onRESNET 301.The ERI shall be computed based on the energy cost of the proposed building compared to the energy cost of the referencedesign building in accordance with Equation 4-1 instead of Section 4.1 of RESNET 301.

ERI = (proposed design) / (reference design). (Equation 4-1)

where,

proposed design = annual energy cost for proposed building

reference design = annual energy cost for reference design building

Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ICC/RESNET 301-2014, Standard for the Calculation and Labeling of the Energy Performance of Low-Rise ResidentialBuildings using the HERS Index,(Republished January 15, 2016)

Reason: This change retains most of the RESNET calculation, but specif ies the use of energy cost. Energy cost is already used in the IECC. Aproposed building w ith an energy cost less than or equal to the IECC building w ould comply.The part of the HERS index calculation replaced by this change is inconsistent w ith the IECC. That calculation, show n below , is effectively proprietary.The IECC should not require a calculation that is only used by those associated w ith RESNET. The "proprietary" calculation w ould become "energy cost"w ith this change. To see how odd that calculation is, just try to read the RESNET calculation below .

The language in ANSI/RESNET 301-2014 that is removed by this change is show n below :

4.1 Determining the HERS Index.The HERS Index for a residential building shall be determined in accordance w ith Sections 4.1.1 and 4.1.2.

4.1.1. Calculating End Use Loads. The normalized Modif ied End Use Loads (nMEUL) for space heating and cooling and domestic hot w ater use shalleach be determined in accordance w ith Equation 4.1-1:

nMEUL = REUL * (nEC_x / EC_r) (Eq 4.1-1)

w here:

nMEUL = normalized Modif ied End Use Loads (for heating, cooling, or hot w ater) as computed using an Approved Softw are Rating Tool.

REUL = Reference Home End Use Loads (for heating, cooling or hot w ater) as computed using an Approved Softw are Rating Tool.

nEC_x = normalized Energy Consumption for the Rated Home's end uses (for heating, including Auxiliary Electric Consumption, cooling or hot w ater) ascomputed using an Approved Softw are Rating Tool.

EC_r = estimated Energy Consumption for the Reference Home's end uses (for heating, including Auxiliary Electric Consumption, cooling or hot w ater)as computed using an Approved Softw are Rating Tool.

and w here:

nEC_x = (a* EEC_x – b)*(EC_x * EC_r * DSE_r) / (EEC_x * REUL) (Eq 4.1-1a)

w here:

EC_x = estimated Energy Consumption for the Rated Home's end uses (for heating, including Auxiliary Electric Consumption, cooling or hot w ater) ascomputed using an Approved Softw are Rating Tool.

EEC_x = Equipment Eff iciency Coeff icient for the Rated Home's equipment, such that EEC_x equals the energy consumption per unit load in like units asthe load, and as derived from the Manufacturer's Equipment Performance Rating (MEPR) such that EEC_x equals 1.0 / MEPR for AFUE, COP or EFratings, or such that EEC_x equals 3.413 / MEPR for HSPF, EER or SEER ratings.

DSE_r = REUL/EC_r * EEC_r

For simplif ied system performance methods, DSE_r equals 0.80 for heating and cooling systems and 1.00 for hot w ater systems [see Table 4.2.2(1)].How ever, for detailed modeling of heating and cooling systems, DSE_r may be less than 0.80 as a result of part load performance degradation, coil airf low degradation, improper system charge and auxiliary resistance heating for heat pumps. Except as otherw ise provided by these Standards, w heredetailed systems modeling is employed, it must be applied equally to both the Reference and the Rated Homes.

EEC_r = Equipment Eff iciency Coeff icient for the Reference Home's equipment, such that EEC_r equals the energy consumption per unit load in like unitsas the load, and as derived from the Manufacturer's Equipment Performance Rating (MEPR) such that EEC_r equals 1.0 / MEPR for AFUE, COP or EFratings, or such that EEC_r equals 3.413 / MEPR for HSPF, EER or SEER ratings and w here the coeff icients 'a' and 'b' are as defined by Table 4.2.1(1)


RE170-16 : R406.3.1-CONNER12917

below :

Table 4.2.1(1) Coefficients "a" and "b"

Fuel type and End Use a b

Electric space heating 2.2561 0

Fossil f uel* space heating 1.0943 0.4030

Biomass space heating 0.8850 0.4047

Electric air conditioning 3.8090 0

Electric water heating 0.9200 0

Fossil f uel* water heating 1.1877 1.0130

*Such as natural gas, liquid propane gas, fuel oil

4.1.2. Calculating the HERS Index. The HERS Index shall be determined in accordance w ith Equation 4.1-2:

HERS Index = PEfrac * (TnML / TRL) * 100 (Eq 4.1-2)

w here:

TnML = nMEULHEAT + nMEULCOOL + nMEULHW + EULLA (MBtu/y).

TRL = REULHEAT + REULCOOL + REULHW + REULLA (MBtu/y).

and w here:

EULLA = The Rated Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.2, converted to MBtu/y, w here MBtu/y =(kWh/y)/293 or (therms/y)/10, as appropriate.

REULLA = The Reference Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.1, converted to MBtu/y, w here MBtu/y =(kWh/y)/293 or (therms/y)/10, as appropriate.

and w here:

PEfrac = (TEU - OPP) / TEU

TEU = Total energy use of the Rated Home including all rated and non-rated energy features w here all fossil fuel site energy uses (Btuf ossil) areconverted to equivalent electric energy use (kWheq) in accordance w ith Equation 4.1-3.

OPP = On-Site Pow er Production as defined by Section 5.1.1.4 of this Standard.

kWheq = (Btufossil * 0.40) / 3412 (Eq 4.1-3)

Cost Impact: Will not increase the cost of constructionThe RESNET 301 standard uses a signif icantly dif ferent calculation from the IECC's energy cost calculation. As a consequence, some have set therequired "score" low er to ensure that a RESNET-scored house is really going to meet the IECC. Moving the RESNET calculation to the IECC-type costcalculation w ill tend to reduce the need to make the ERI score so low . Therefore, by aligning the IECC and RESNET calculation this proposed change w illtend to reduce the cost of construction.


RE171-16 : R406.3.1-DRUMHELLER13038

RE171-16R406.3.1 (IRC N1106.3.1)Proponent : Craig Drumheller ([email protected])



The proposed residential building shall be shown to have an annual energy cost or annual total normalized modified load lessthan or equal to the annual energy cost or total loads annual load of the ERI reference design.

Reason: The current ERI Compliance Alternative requires a "normalized modif ied load" calculation for both the reference design and the proposeddesign. This normalized modif ied load calculation is embedded in the RESNET process, but no other providers offer this type of calculation. A cost basedcompliance calculation w ould allow other providers to participate in the process.Currently softw are that performs ERI (HERS Index) calculations is only available to certif ied HERS raters. Changing this to a cost analysis w ould allownon-HERS raters to perform this type of calculation based on the annual energy cost of the proposed design divided by a 2006 IECC reference design.

Using cost as the ERI compliance metric has been determined to be slightly harder to achieve than the normalized modif ied load. An analysis performedby Philip Fairey for the ASHRAE 90.2 committee show ed that the cost approach w ould be roughly 4-5 points higher than using the RESNET approach.So builders using this method may need to increase the eff iciency in the house in order to comply, but there may be areas in the country w here theremay not be adequate availability of raters and this calculation w ould be the most practical approach.

Cost Impact: Will increase the cost of constructionFor builders using the cost approach rather than the ERI may need to include additional measures to achieve the additional requirements necessary tomeet the cost based ERI values.


RE172-16 : TABLE R406.4-DRUMHELLER13051

RE172-16Table R406.4 (IRC Table N1106.4)Proponent : Craig Drumheller ([email protected])




1 5268

2 5266

3 5164

4 5467

5 5570

6 5468

7 5370

8 5365

Reason: It is w idely understood that the Energy Rating Index target values in Table R406.4 are not equivalent to that of the prescriptive path. In fact, thevalues are on the order of 30% or more stringent than the 2015 IECC prescriptive path according to a study by the Dillon Group (Dillon). This additionalstringency w as by design w hen developing the original ERI proposal. A series of assumptions w ere made artif icially low ered the score so far makingthe ERI path virtually unusable. In developing the ERI values, all equipment w as assumed to be high eff iciency, a 5% assumption in the increase instringency from the 2012 to the 2015 IECC (actually 1%), then an additional 10% reduction w as taken- making the w hole building energy consumptionnearly half of w hat it w as in the 2006 IECC. This proposal modif ies the Index values in all climate zones to be roughly 15% more stringent than the prescriptive path. This provides a f lexible ERI paththat includes equipment eff iciency trade-offs and credit for on-site generation, but requires a reasonable amount of additional energy savings over thatof the prescriptive path.

Bibliography: 2015 IECC Equivalent HERS Index Values, The Dillon Group, 2015 (Page 2)

Cost Impact: Will not increase the cost of construction This proposal w ill reduce the cost of construction for homes using the Energy Rating Index to comply w ith the energy code. The index numbers w ill beincreased (less stringent) than the existing numbers by betw een 18 and 24%. How ever, the ERI w ill still be more energy eff icient that the prescriptivepath.


RE173-16Table R406.4 (IRC Table N1106.4)Proponent : Amanda Hickman, InterCode Incorporated, representing Leading Builders of America ([email protected])




1 5257

2 5257

3 5157

4 5462

5 5561

6 5461

7 5358

8 5358

Reason: Some estimates have put the ERI scores for homes built to the 2015 prescriptive code as high as 79. This proposal is intended to producesubstantial additional energy savings compared to the current or proposed levels of prescriptive requirements in the 2015 IECC, w hile allow ingconsiderably greater f lexibility to builders using a method w ith w hich a large segment of the market is already familiar. This f lexibility is likely to result inlow er construction costs for any given level of energy eff iciency. Builders w ho do not make use of this proposed method are still able to comply w iththe code using any of the existing compliance pathw ays.

The revised ERI values in the proposal w ere based on an additional 10 percent savings beyond 2012 w ith 2014 NAECA HVAC and w ater heatingequipment eff iciencies. The values can also be achieved using heating, cooling, and w ater heating equipment eff iciency levels higher than NAECAminimum levels in the Northern and Southern parts of the country. The resulting ERI values are considered cost effective in all climate zones and w illresult in increased eff iciency for residential construction over the 2012 IECC.

While the ERI values w ill provide f lexibility, the 2009 IECC residential envelope requirements have been set as a backstop in the ERI path for the leasteff icient level of eff iciency for insulation R-values, glazing U-factor and SHGC. This proposal also requires complying w ith the applicable mandatoryrequirements to be consistent w ith the Above Code section in the IECC. And because energy losses in the domestic hot w ater distribution system falloutside the scope of the energy rating index as it can be calculated w ith 2012 methodology, current code provisions relating to hot w ater pipe insulationare mandatory as w ell.

Since the f inal action hearings and publication of the 2015 IECC, the "Standard for the Calculation and Labeling of the Energy Performance of Low -RiseResidential Buildings using the Energy Rating Index" (ANSI/RESNET/ICC 301-2014) w as published. This standard development change required softw arevendors to make changes to their softw are to comply w ith the requirements of the new standard.

These changes have caused the ERI scores to increase by an estimated 2 to 3 points due to inf iltration and ventilation changes, and decrease by anestimated 1 to 2 points due to changes related to eff icient domestic w ater heating. This results in a net change of 1 to 2 points in ERI Scores.

The proposed ERI numbers take all of the aforementioned adjustments into account.

Sources:

1. RE188-13 Public Comment #2 Reason statement: Eric Makela, Britt/Makela Group, representing self, Ron Burton, representing Leading Buildersof America, David Goldstein, representing National Resource Defense Council, and Meg Waltner, representing National Resource DefenseCouncil

2. "Upcoming Changes to the HERS Index and Potential Impact on HERS Index Scores"

Bibliography:


RE173-16 : TABLE R406.4-HICKMAN13156

Cost Impact: Will not increase the cost of constructionBecause this proposal provides more f lexibility, it is likely to result in low er construction costs for any given level of energy eff iciency.


RE174-16 : TABLE R406.4-URBANEK13029

RE174-16R406.4 (N1106.4)Proponent : Lauren Urbanek, Natural Resources Defense Council ([email protected])

2015 International Energy Conservation CodeR406.4 (N1106.4) ERI-based compliance. Compliance based on an ERI analysis requires that the rated design be shown tohave an ERI less than or equal to the appropriate value listed in Table R406.4 when compared to the ERIreference design.



1 5251

2 5251

3 5149

4 5452

5 5552

6 5451

7 5350

8 5351

Reason: The purpose of this proposal is to increase the eff iciency of homes built to the Energy Rating Index by 1-3 points to account for savingsachievable through hot w ater eff iciency improvements that w ere not previously considered in the target ERI scores. As building component technologyand the eff iciency of systems and equipment continues to improve, it is important to continue to promote ever-increasing levels of eff iciency in the IECC.When the ERI targets w ere set during the 2015 code cycle, the primary rating system used to calculate compliance, the RESNET HERS system, could notcalculate energy savings from certain hot w ater energy eff iciency measures. The RESNET HERS system has since been modif ied to account for energysavings from certain hot w ater eff iciency measures. These savings are based on simple and inexpensive measures such as low er-f low plumbingfittings and hot w ater layouts that minimize w ater w aste.

By strengthening the ERI scores in Table R406.4, the IECC w ill drive further innovation, better building practices, and more energy cost savings forhomeow ners.

Cost Impact: Will not increase the cost of construction This proposal adjusts the values for compliance in the ERI pathw ay by 1-3 points. How ever, this w ill not have an impact on the cost of constructionunder the ERI pathw ay because of recent changes made to the RESNET HERS system (the predominant rating system used for the ERI pathw ay).Previously, the HERS score w as not able to account for energy eff iciency savings from hot w ater eff iciency measures. The HERS score w as recentlyimproved to account for these hot w ater eff iciency measure that are already w idely installed by builders at no incremental cost. These improvementsinclude low -f low f ixtures (a 1.6 GPM show erhead is equivalent in price to a higher-f low show erhead, per prices at Home Depot) and eff icient plumbinglayouts (this can actually reduce a builder's cost due to the use of few er materials).

Analysis performed by the Florida Solar Energy Center determined the impact on the HERS score from these common hot w ater eff iciency measures,and that analysis w as directly used to adjust the scores in the proposal. There is no net impact on a builder – the HERS score is now just able toaccount for w hat is already happening as common building practice. This proposal simply takes into account w hat is already happening in themarketplace and adjusts the ERI pathw ay to account for changes in the w ay the HERS score operates.

Furthermore, this proposal makes changes to an optional path. A builder w ould only pursue this path voluntarily, or if they could comply more cheaplyand easily than another path.


RE175-16R406.4.1 (New) [IRC N1106.4.1 (New)], Table R406.4.1 (New) [IRC Table N1106.4.1 (New)], R406.6.2(IRC N1106.6.2)Proponent : Vickie Lovell, InterCode Incorporated, representing Leading Builders of America ([email protected])


R406.4.1 (N1106.4.1) On-site power production. Where on-site power is provided, the contribution of power produced on-siteto the ERI shall not exceed the percentages specified in Table R406.4.1


ENERGY RATING INDEX (ERI) of the Rated Design % CREDIT FOR ON-SITE POWER PRODUCTIONa

65 and abov e 0

64 5

63 10

62 15

61 20

60 25

59 30

58 35

57 40

56 45

55 50

54 55

53 60

52 65

51 70

50 75

49 80

48 85

47 90

46 95

45 and below 100


RE175-16 : R406.4.1 (NEW)-LOVELL12664


Revise as follows:



checklist shall show results for both the ERI reference design and the rated design, and shall document all inputs,including the percentage of power produced on-site credited to the ERI, entered by the user necessary to reproducethe results.



Reason: This proposal creates an easy to enforce method that recognizes on-site pow er production, but LIMITS THE CREDIT FOR POWER PRODUCEDON-SITE THAT MAY BE APPLIED TO THE CALCULATION OF THE ERI.The CONCEPT –The International Code Conservation Code should not be inconsistent w ith the federal policy (and many state statutes) that encourage national energyindependence through conservation, and incentivizes the use of on-site pow er generation in residential buildings. This proposal creates a compliancemethod that is easy to enforce and a design tool that is easy to use and understand.

A method for calculating for on-site pow er in the ERI is not currently required anyw here in Section 406. This proposal does NOT require on-site pow erproduction to be calculated in the ERI. It only limits how much on-site pow er is allow ed to be considered in calculating the ERI if and w hen the designerchooses to incorporate on-site pow er in the total energy use of the rated design.

The new Table 406.6.1 promotes both energy conservation and energy production. It accomplishes this by driving improvements in the buildingenclosure and installed mechanical systems in order to earn greater contributions from the production of on-site pow er w hile maintaining the protectionsof meeting the code envelope requirements and mandatory measures in the 2009 IECC.

Homes currently have to meet the mandatory building requirements of the 2009 IECC. That does not change w ith the implementation of the new Table406.4.1. Compliance w ith the 2009 "backstop" provisions ensure that the building itself is eff icient.

The METHOD –

The proposed new Table 406.4.1 starts crediting on-site pow er at an ERI of 64 and moves in 5% increments per integer until 100% of on-site pow erproduced may be applied to the ERI. The percentages in Table 406.4.1 represent those 5% increments.

The value of 65 for w as selected for the Table 406.4.1 because it is the AVERAGE HERS RATING of over 610,000 new homes built since 2012 asreported by RESNET.

The designer can adjust the rated design by calculating exactly w hat percentage of the on site pow er may be utilized in the rated design to achieve acode compliant ERI scores found in Table 406.4

The new Table 406.4.1 is also designed to account for ERI scores that states and local jurisdiction may adopt that are both above and below the ERIvalues currently listed on Table R406.4. Table 406.4 is adaptable to states and local jurisdictions that are adopting different ERI scores different fromw hat is contained in the 2015 IECC, such as Texas that adopted an ERI score of 65. The values in Table R406.4.1 can be applied to these higher ERIscores w hich w ould limit on-site pow er production consistently from state to state regardless of the ERI adopted by the states. The low er values (morestringent) than the current Table R406.4 values also "future proof" the table to account for more stringent ERI scores in later versions of the IECC.

The ENFORCEMENT –

Compliance w ith Table 406.4.1 is easy. The code off icial or plan review er only has to review the compliance report for the ERI score that is required forthe climate zone in Table 406.4. The code off icial or plan review er then needs to verify that that the percentage of on-site pow er cited in the compliancereport is consistent w ith percentage listed in Table 406.4.1.There is a companion proposal to this change to require that the percentage of onsite pow erused in the ERI in found in the compliance report.

The CONCLUSION

Enabling new paths to achieve energy eff iciency creates new opportunities for even greater innovation is part of the stated purpose of the IECC. Thisis yet another option, the most stringent yet f lexible of all the compliance options w ithin the IECC, for consumers and builders. Pow er produced on-site isgaining steadily in popularity w ith homeow ners and can help reduce the compliance costs for builders, making homes more affordable to build and tolive in.

Cost Impact: Will not increase the cost of constructionBecause on-site pow er production is not required to achieve code compliant Energy Rating Index values and this proposal only limits the amount of on-site pow er produced that can be applied to reduce the ERI to achieve code compliance, there is no direct cost impact.Cost-effectiveness: This change is cost-effective because it is expected to provide neutral or positive energy impact and builders are not required touse on-site pow er production to reach code compliant Energy Rating Index values.


RE176-16R406.4.1 (New) [IRC N1106.4.1 (New)], Table R406.4.1 (New) [IRC Table N1106.4.1 (New)], R406.6.2(New) [IRC N1106.6.2 (New)]Proponent : Eric Makela, Cadmus, representing RESNET


R406.4.1 (N1106.4.1) On-site power production. The power produced on-site shall be included in the calculation fordetermining the ERI value in accordance with ANSI ICC/RESNET 301. The contribution to the ERI calculation shall be 5% ofthe on-site power produced for each ERI point less than 65 as specified in Table R406.4.1.


ENERGY RATING INDEX PERCENT CREDIT FOR ON-SITE POWER PRODUCTIONa

65 and abov e 0

64 5

63 10

62 15

61 20

60 25

59 30

58 35

57 40

56 45

55 50

54 55

53 60

52 65

51 70

50 75

49 80

48 85

47 90

46 95


RE176-16 : R406.4.1 (NEW)-MAKELA13307

45 and below 100




checklist shall show results for both the ERI reference design and the rated design, and shall document all inputs,including the percentage of power produced on-site credited to the ERI, entered by the user necessary to reproducethe results.



Reason: RESNET supports limiting the credit that on-site pow er production provides w hen determining an ERI score for demonstrating compliance w iththe energy code. The limitation ensures that the eff iciencies of the building envelope, heating and cooling system, and lighting are not traded aw ay bythe use of on-site pow er production.Table 406.4.1 only allow s a percentage of the total amount of on-site pow er produced to be considered based on the Target ERI score included in TableR406.4. The look-up table w ill inform both the builder and the code off icial on the percentage of onsite pow er that can be credited w hen generating theERI score.

For example, a home proposed to be built in Climate Zone 2 w ould have a target ERI score from Table R406.4 of 52. Table R406.4.1 show s that 65% ofthe proposed on-site pow er produced could be credited tow ard the building to generate the ERI score. If a 5 kW photovoltaic system is proposed for thehouse for on-site pow er production, credit can only be taken for 3.25 kW (0.65 X 5kW).

The code change proposal then requires that the percentage of on-site pow er assumed for the project is printed on the report that is submitted as partof the energy code documentation.

When on-site pow er production is utilized in the residential building design, such pow er may be permitted to reduce the Energy Rating Index (ERI) for theresidential building w ith an ERI of less than 65. The proposed new table starts crediting such pow er at an ERI of 64 and moves in 5% increments perinteger until 100% of on-site pow er produced may be applied to the ERI. The value of 65 w as selected because it is the AVERAGE HERS RATING ofover 610,000 new homes built since 2012 as reported by RESNET.

The Table is also designed to account for Target ERI scores that states and local jurisdiction may adopt that are both above and below the ERI valueslisted on Table R406.4. The table recognizes that not all states and local jurisdictions are adopting the ERI scores as contained in the 2015 IECC, such asTexas that adopted an ERI score of 65. The values in Table R406.4.1 can be applied to these higher ERI scores w hich w ould limit on-site pow erproduction. The values low er (more stringent) than the Table R406.4 values also "future proof" the table to account for more stringent ERI scores in laterversions of the IECC.

Cost Impact: Will not increase the cost of constructionNone. The ERI approach is an alternative compliance approach other compliance approaches can be used if the additional f irst cost due to the cap onon-site energy production impacts the f irst cost of the project.



RE177-16 : R406.4.1 (NEW)-MERES12703

RE177-16R202 (New) [IRC N1101.6 (New)], R406.4.1(New) [IRC N1106.4.1 (New)], Table R406.4.1(New) [IRCTable N1106.4.1 (New)]Proponent : Ryan Meres, Institute for Market Transformation ([email protected])


R202 (N1101.6) RENEWABLE ENERGY. Energy derived from solar radiation, wind, waves, tides, landfill gas, biomass or theinternal heat of the earth.


R406.4.1 (N1106.4.1) Renewable energy. The use of on-site renewable energy is allowed to meet the values specified inTable R406.4 where the ERI for the proposed residential building without renewable energy is less than or equal to the value forthe appropriate climate zone specified in Table R406.4.1.

TABLE R406.4.1 (N1106.4.1) Maximum Energy Rating Index Without Renewable Energy


1 57

2 57

3 57

4 61

5 61

6 61

7 58

8 58

Reason: The purpose of this proposal is to create a reasonable pathw ay to allow credit for on-site renew able energy in the 2018 IECC. The HERS rating system allow s a home to have unlimited renew able energy: a home can have a HERS score of zero, w hich necessitates a signif icantcontribution of renew able generation. This is the right approach for a rating system, but is not the right approach for a code. While a rating systemencourages competition among home builders and can be used effectively to assess both new and existing homes, the purpose of a conservation codeis to conserve energy by increasing a home's energy eff iciency.

The ERI levels set in the 2015 code w ere set based on calculations of cost-effective energy eff iciency levels, including trade-offs made against variousbuilding envelope options. The analysis during the development of the 2015 ERI levels did not account for the impact of renew able energy generation. Amedium-sized solar installation is w orth approximately 35 points. If unlimited renew able generation w as allow ed to count tow ard the ERI score, there isthe potential for a substantial portion of the ERI score to be met w ith renew able systems, resulting in homes that are even less eff icient than the 2009code. Allow ing unlimited renew able generation w ould mean that homes could be built w ith few er eff iciency measures, w hich w ould move thestringency of the code backw ard.

Builders may have additional incentive to prioritize PV over eff iciency. Given the innovative f inancing options available, builders may be able to w orkw ith solar companies to install PV at no cost of materials or construction. In this situation, the homeow ner then enters into a pow er purchase agreementdirectly w ith the solar provider. If solar is allow ed as a substitute for eff iciency, the baseline home w ill use more energy, the solar system w ill need tobe larger (and therefore more expensive), and the home w ill be more vulnerable to higher bills if and w hen the solar system is removed. None of theseissues factor into the builder's decision-making, but they directly affect the homeowner over the lifetime of the home. The code is in place to ensure thathome buyers receive a high-quality product that is relatively standardized, no matter w here or by w hom the home is built. Allow ing unlimited renew ablecredit to take the place of eff iciency measures in the code adds uncertainty for the home buyer.

In addition to the energy conservation intent of the code, homeow ners benefit from a more eff icient home even if much of their load is offset by PV oranother renew able source. Energy eff iciency upgrades promoted in the code, like insulation and air sealing, are essentially permanent and diff icult toremove. While the lifespan of solar panels is improving, the output of the panels decreases over time. A homeow ner w ill eventually need to replace thepanels, w hich w ill come at an added expense. Furthermore, the homeow ner could choose to remove the panels at virtually any time. If a home isdesigned to be built less-eff iciently, w ith solar panels making up the difference, then the homeow ner is left w ith a baseline home that w ill consume moreenergy over its lifespan.

Cost Impact: Will not increase the cost of constructionThis code change proposal, in and of itself, w ill not increase the cost of construction. This proposal only affects homes installing solar panels and usingthe ERI compliance path, w hich is only one compliance option and w ill not increase the cost of construction available to the builder under othercompliance options.


RE178-16 : R406.6.2-SCHWARZ12453

RE178-16R406.6.2 (IRC N1106.6.2), R406.6.2.1 (New) [IRC N1106.6.2.1 (New)], R406.6.2.2 (New) [IRCN1106.6.2.2 (New)]Proponent : Robby Schwarz, representing EnergyLogic, Inc. ([email protected])


R406.6.2 (N1106.6.2) Compliance report. Compliance software tools shall generate a report that documents documentingthat the ERIproposeddesign complies with sections R406.2 through R406.4. A compliance report on the proposed design shallbe submitted with the application for the building permit. Upon completion of the building, a compliance report based on the as-built condition of the building shall be submitted to the rated design code compliesofficial before a certificate of occupancy isissued. Batch sampling of buildings to determine energy code compliance shall only be allowed for stacked multifamily units.Compliance reports shall include information in accordance with Sections R406.3 and R406.4. The Where the proposed designof a building could be built on different sites where the cardinal orientation of the building on each site is different, compliancedocumentation of the proposed design for the purposes of the application for the building permit shall include be based on thefollowing information:





worst-case orientation, worst-case configuration, worst-case building air leakage and worst case duct leakage. Such worst-case parameters shall be used as inputs to the compliance software for energy analysis.


R406.6.2.1 (N1106.6.2.1) Compliance report for permit application. A compliance report submitted with the applicationfor building permit shall include the following:

1. Building street address, or other building site identification.2. A statement indicating that the proposed design complies with Section R406.2.3. An inspection checklist documenting the building component characteristics of the rated design. The inspection


4. A site-specific energy analysis report that is in compliance with Section R406.3 through R406.4.5. The name of the individual performing the analysis and generating the report.6. The name and version of the compliance software tool.

R406.6.2.2 (N1106.6.2.2) Compliance report for certificate of occupancy . A compliance report submitted for obtainingthe certificate of occupancy shall include the following:

1. Building street address or other building site identification.2. A statement indicating that the as-built building complies with Section R406.3.3. A certificate indicating that the building passes the ERI matrix for code compliance and listing the energy saving

features of the buildings.4. A site-specific energy analysis report that is in compliance with Section R406.3 through R406.4.5. The name of the individual performing the analysis and generating the report.6. The name and version of the compliance software tool.

Reason: This proposal carries over the process map clarif ication for generating compliance documentation from the simulated performance pathsection R405 to the ERI path section R406 as the process is identical for generating permitting and f inal certif icate of occupancy reports. It is importantto further define the process so all understand w hat is required in addition to the generation of the ERI score.

Cost Impact: Will not increase the cost of constructionThere is not cost implication for this proposal as everything outlined must already occur to utilize the ERI path. Rather this proposal ensures a commonunderstanding of the process for utilizing section R406.


RE179-16R202 (New) [IRC N1101.6 (New)], R401.2 (IRC N1101.13), R407(New) [IRC N1107 (New)], R407.1(New) [IRC N1107.1 (New)], R407.2 (New) [IRC N1107.2 (New)], Table R407.3.1 (New) [IRC TableN1107.3.1 (New)], R202(N1101.6) (New)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, representing Building Codes Assistance Project ([email protected]); Harry Misuriello,American Council for an Energy-Efficient Economy (ACEEE), representing Energy Efficient Codes Coalition; Jeffrey Harris, Alliance toSave Energy, representing Alliance to Save Energy; William Prindle, ICF International, representing Energy Efficient Codes Coalition


R401.2 R401.2(N1101.13) Compliance. Projects shall comply with one of the following:

1. Sections R401 through R404 and Section R407.2. Section R405, Section R407 and the provisions of Sections R401 through R404 labeled "Mandatory."3. An energy rating index (ERI) approach in Section R406 and the provisions of Section R407.


SECTION 407(N1107) ADDITIONAL ENERGY EFFICIENCY (MANDATORY)

R407.1(N1107.1) Scope. This section establishes additional mandatory requirements applicable to all compliance approachesto achieve additional energy efficiency.

R407.2(N1107.2) Points-based compliance. One or more energy efficiency measure(s) shall be installed in accordance withSection R407.3 that cumulatively equal or exceed 5 (five) Flex Points for the appropriate Climate Zone. Projects complyingunder the simulated performance alternative outlined in Section R405 shall demonstrate compliance with Section R405 withoutincluding in the proposed design any features that will be utilized to comply with Section R407. Projects complying under theenergy rating index alternative outlined in Section R406 shall demonstrate compliance with Section R406 without including inthe proposed design any features that will be utilized to comply with Section R407.

Exceptions: The requirements of this section shall not apply to:

1. Projects complying under the performance approach outlined in Section R405, where the proposed design undersection R405.3 is shown to have an annual energy cost that is less than or equal to 95% of the annual energy costof the standard reference design.

2. Projects complying under the energy rating index approach outlined in Section R406, where the project has amaximum energy rating index value at least 5% less than the index target specified in Table R406.4.

3. Additions with a conditioned floor area equal to or less than 1,000 square feet.4. Alterations, renovations and repairs to an existing building.

R407.3.1(N1107.3.1) Flex Points for additional energy efficiency. Measures shall be selected from Table R407.3.1. Eachmeasure chosen shall receive credit for the Flex Points as indicated in the Table for the specific Climate Zone. Interpolation ofpoints between measures shall not be permitted.

Revise as follows:

TABLE R407.3.1(N1107.3.1) FLEX POINTS FOR ADDITIONAL ENERGY EFFICIENCY

Measure

Number

Measure Description Flex Point Value

CZ

1

CZ

2

CZ

3

CZ

4

CZ

4C

CZ

5

CZ

6

CZ

7

CZ

8

1a ≥ 2.5% reduction in total UA b 1 1 2 2 2 2 3 4 4

1b ≥ 5% reduction in total UA b 3 3 3 3 3 4 5 5 5

1c ≥ 7.5% reduction in total UA b 5 5 5 5 5 6 7 8 8

1d ≥ 10% reduction in total UA b 6 7 7 7 8 8 9 10 10

2a ≥ 10% reduction in glazed f enestration area-weighted av erage SHGC 2 1 - - - - - - -

2b ≥ 20% reduction in glazed f enestration area-weighted av erage SHGC 4 1 - - - - - - -


3a ≤ 4 ACH50 air leakage rate with ERV or HRV installed c 1 2 - - - - - - -

3b ≤ 3 ACH50 air leakage rate with ERV or HRV installed c 2 4 5 7 7 7 7 8 8

3c ≤ 2 ACH50 air leakage rate with ERV or HRV installed c 2 5 7 9 9 9 10 11 11

4a ≤ 2 CFM of total duct leakage per 100 square f eet of conditioned f loor area when tested

in accordance with Section R403.2.2

1 1 1 1 - 1 1 1 1

4b 100% of duct thermal distribution sy stem located in conditioned space 1 1 1 1 1 1 2 2 2

4c 100% of duct thermal distribution sy stem located in directly conditioned space d 8 8 9 11 8 12 15 17 17

4d 100% of ductless thermal distribution sy stem located completely inside the building

thermal envelope

8 8 9 11 8 12 15 17 17

4e 100% of hy dronic thermal distribution sy stem located completely inside the building

thermal envelope

8 8 9 11 8 12 15 17 17

5a ≥ 16 SEER and ≥ 13 EER cooling sy stem ef f iciency e 5 4 1 1 - - - - -

5b ≥ 18 SEER and ≥ 14 EER cooling sy stem ef f iciency e 9 7 3 2 - - - - -

5c ≥ 16 EER cooling sy stem ef f iciency e 10 7 3 2 - - - - -

5d ≥ 18 EER cooling sy stem ef f iciency e 13 10 4 2 - 1 - - -

5e ≥ 20 EER cooling sy stem ef f iciency e 16 12 5 3 - 1 - - -

5f ≥ 24 EER cooling sy stem ef f iciency e 22 19 12 4 - 1 - - -

5g ≥ 28 EER cooling sy stem ef f iciency e 25 21 13 5 - 1 - - -

6a ≥ 95 AFUE heating sy stem ef f iciency f - 2 6 8 9 10 11 12 13

6b ≥ 96 AFUE heating sy stem ef f iciency f - 2 6 9 10 10 11 12 14

6c ≥ 98 AFUE heating sy stem ef f iciency f - 3 7 10 11 12 13 14 15

7a ≥ 9.5 HSPF heating sy stem ef f iciency f - - 1 2 2 2 2 2 1

7b ≥ 10.5 HSPF heating sy stem ef f iciency f - 1 2 4 4 5 4 3 3

7c ≥ 3 COP heating sy stem ef f iciency f - 1 2 3 3 4 3 3 2

7d ≥ 3.5 COP heating sy stem ef f iciency f - 2 4 6 6 8 7 6 5

7e ≥ 4 COP heating sy stem ef f iciency f - 2 5 8 9 10 10 9 7

7f ≥ 4.5 COP heating sy stem ef f iciency f - 2 5 9 10 11 11 10 8

7g ≥ 5 COP heating sy stem ef f iciency f - 3 6 10 11 12 12 12 9

8a ≥ 0.7 EF f or f ossil f uel serv ice water heating sy stem 2 2 - - - - - - -


8b ≥ 0.8 EF f or f ossil f uel serv ice water heating sy stem 7 5 4 3 2 2 2 1 1

8c ≥ 0.95 EF f or electric serv ice water heating sy stem - - - - - - - - -

8d ≥ 1.15 EF f or electric serv ice water heating sy stem 7 7 7 4 5 3 3 2 2

8e ≥ 0.4 Solar Fraction f or serv ice water heating sy stem 8 9 9 7 9 6 5 4 3

a. Climate Zone 4C is Climate Zone Marine 4.

b. The Total UA shall be calculated in accordance with Section R402.1.4 Total UA alternative.c. Minimum Heat Recovery Ventilator (HRV) and Energy Recovery Ventilator (ERV) requirements, measured atthe lowest tested net supply airflow, shall be ≥ 75% Sensible Recovery Efficiency (SRE), ≤ 1.1 W/CFM FanEnergy and shall not use recirculation as a defrost strategy. In addition, the Energy Recovery Ventilator (ERV)shall be ≥ 50% Latent Recovery/Moisture Transfer (LRMT).d. To achieve 100% of the thermal distribution located in the actively conditioned space, no ducts used for theheating and cooling systems shall be located within walls or ceilings or other locations where all of the losses arenot directly into the conditioned space.e. For multiple cooling systems, all systems shall meet or exceed the minimum efficiency requirements in TableR407.3.1 and shall be sized to serve 100% of the cooling design load. As an alternative, each system installedshall receive credit for the percentage of the Flex Points for the measure equal to the percentage of the coolingdesign load served by the system.f. For multiple heating systems, all systems shall meet or exceed the minimum efficiency requirements in TableR407.3.1 and shall be sized to serve 100% of the heating design load. As an alternative, each system installedshall receive credit for the percentage of the Flex Points for the measure equal to the percentage of the heatingdesign load served by the system.


R202(N1101.6) DIRECTLY CONDITIONED SPACE An area within conditioned space that is directly heated or cooled tomaintain heating and cooling temperature setpoints, including any habitable room. Directly conditioned space shall not includeindirectly conditioned space.

R202(N1101.6) INDIRECTLY CONDITIONED SPACE. An area within conditioned space that is not directly heated or cooled,including wall cavities, floor cavities, ceiling cavities, storage rooms, closets, non-habitable attic, non-habitable basement,crawlspace, spaces or cavities that contain uninsulated ducts or thermal distribution systems or have an opening directly intoan adjacent conditioned space. Spaces are indirectly heated or cooled where they communicate through openings withconditioned spaces, where they are separated from conditioned spaces by uninsulated walls, floors or ceilings, or where theycontain uninsulated ducts, piping or other sources of heating or cooling.

Reason: The purpose of this code change is to establish a new mandatory section to achieve additional energy eff iciency. This proposal w ill allowbuilders the f lexibility to choose from a menu of options to achieve 5% or more in energy savings beyond compliance w ith the current prescriptive,performance and ERI paths in the 2015 IECC. These new mandatory set of points-based options are predicated on the notion that because the currentresidential I-Codes require a solid foundation of "w hole house" eff iciency features, builders should have f lexibility to determine the improvements thatadd onto that foundation. In addition to bringing about a reasonable, but modest, improvement in energy eff iciency as compared to the 2015 IECC, theproposal w ill also lay the groundw ork for emerging technologies and future improvements to the code. Similar options-based approaches are currentlyfound in both the commercial provisions of the 2015 IECC (section C406) and in residential energy codes adopted in some states. As discussed below ,this proposal improves the IECC in at least f ive important w ays.

The proposal improves the overall energy efficiency of the IECC and IRC by about five percent, reducing the home's energyconsumption and homeowner operating costs.From a national energy policy standpoint, the need to improve the eff iciency of America's buildings has not changed. Because buildings continue toconsume over 50% of the natural gas and over 70% of the electricity consumed in America, the nation's building codes should incorporate reasonablemeasures to reduce energy use and peak demand w herever feasible. The residential requirements of the 2012 (also reflected in the 2015 IECC)represents a signif icant improvement over previous editions of the code, and w e believe that an additional 5% improvement in eff iciency over the 2012and 2015 IECC is not only feasible, but is crucial to sound national energy policy and our nation's energy future. Each new building and substantialaddition should bring the country one step closer to our national goal of energy independence.

In addition, energy eff icient construction generates signif icant operating savings that quickly recoup the incremental cost of these improvements to newhomebuyers. For example, w hen the US Department of Energy compared homes built to the 2012 IECC w ith homes built to the 2006 IECC, averagehomeow ner life-cycle (30-year) cost savings ranged from $4,763 in Climate Zone 2 (the low est savings in all climate zones) to $33,105 in Climate Zone8 (the highest savings). And, even after accounting for the incremental up-front costs of mortgage fees and dow n payment, a homeow ner'scumulative cash f low became positive w ithin a year or tw o in all eight climate zones.

The proposal creates a highly flexible method to achieve additional energy savings that would be difficult to prescriptively require inthe current IECC and IRC structure.Although there are many possible improvements beyond the 2015 IECC, some of these improvements w ould be impractical or dif f icult to include asspecif ic prescriptive requirements for all homes at this time. For example, some emerging technologies may save energy, but because of limitedavailability, high cost, or federal law s, it may not be reasonable – or even legal – to require these technologies in every building. The IECC does notcurrently have an organized method for recognizing specif ic prescriptive options beyond the baseline requirements.

This proposal creates such an approach and format that recognizes the energy savings potential of a range of systems and building features thatotherw ise w ould not be feasible to include in the baseline requirements at this time. For example, the proposal includes high-eff iciency heating, cooling,and w ater heating options that the code may not be able to require outright because of federal preemption issues. The proposal also includesenvelope-only measures that rew ard builders for going w ell beyond the current code requirements. The result is a reasonably f lexible system of


RE179-16 : R401.2-FAY12487

options that builders can choose from that goes beyond the 2015 IECC and IRC baseline, provides incentives for good building practice andtechnologies, and gives jurisdictions an easily-adaptable, and easy to administer method to set ever-improving eff iciency requirements.

The proposal lays the groundwork for future improvement in the code by establishing a structure for both prescriptive- andperformance-based compliance options.In order to maximize f lexibility and prepare for future improvements to the code, this proposal establishes multiple methods of compliance for newbuildings and additions of more than 1,000 square feet (smaller additions, alterations, renovations and repairs are currently proposed to be exempt toavoid unnecessary complexity) and w ill make further eff iciency improvements in future cycles much easier.

For code users w ho prefer a straightforw ard points-based approach to code compliance, Section R406 outlines a number of options for each climatezone that can be combined for a total of at least 5 points. Each point represents roughly a one percent decrease in the present value of energy costsover the life of the building (so 5 points equal roughly a 5% improvement in eff iciency over the 2015 IECC).

For code users w ho w ish to use the simulated performance alternative in Section R405, the proposal also allow s compliance w here theproposed design demonstrates an energy cost less than or equal to 95% of the energy cost of the standard reference design. The proposalalso allow s, as an alternative, compliance w ith the points system so long as the user does not "double count" in its performance analysis anyimprovements used in points compliance.For code users w ho w ish to use the ERI compliance alternative in Section R406, the proposal also allow s compliance w here the proposeddesign demonstrates an ERI f ive percent or more below the target ERI. The proposal also allow s, as an alternative, compliance w ith the pointssystem so long as the user does not "double count" in its ERI analysis any improvements used in points compliance.

These compliance options can be easily updated in the future. For example, as additional technologies and building practices are improved in the future,these technologies can be added to the table, along w ith a corresponding point value, w ithout a total rew rite of the code.

Points have been calculated based on the present value of energy cost savings over the current code (w ith recognition of relevant federal equipmentstandards), after ref lecting the estimated useful life of each measure and an assumed 30-year life of the building for purposes of the analysis(consistent w ith a 30-year mortgage).

This approach factors in the durability and useful life of each additional option chosen, recognizing that it is not the energy cost savings in the f irst yearthat is critical, but the cost savings over the life of the home that is most important. Although no building energy simulation on this scale w ill be perfect,the analysis behind the Flex Points tables is among the most sophisticated and detailed of its type. The analysis used the Department of Energy buildinganalysis and present value calculation methodology, w hich w ill allow for easy updates to the table in the future. The analysis includes 105 TMY3w eather locations and 12 building types to account for varying stories, foundations and fuel types for each of the baseline and upgrade measures. This analysis w as conducted by ICF International, w hich conducts similar types of analyses for a number of governmental entities, utilities and others.

The proposal creates incentives for code users to consider installing high-efficiency heating, cooling, and water heating systems, aswell as other alternatives, without degrading the thermal building envelope or violating federal law.Code-w riting organizations have long w restled w ith the dilemma of how to incorporate high-eff iciency heating, cooling, and w ater heating systemrequirements into the code w ithout violating federal law and w ithout sacrif icing improvements to the thermal envelope in return. In past code cycles,EECC w as instrumental in removing the equipment trade-offs from the code to resolve the issues these trade-offs and the federal law s created. Weremain strongly committed to that approach today. How ever, this proposal takes the next step by leaving the 2012 IECC baseline requirements intact,w hile offering code users the choice of equipment upgrades among several other potential improvements beyond the baseline requirements. In anattempt to reduce signif icant free ridership, equipment choices are limited to those likely above the typical equipment that w ould be installed anyw ay.

The proposal allows jurisdictions to "try out" a wide variety of efficiency measures that would be difficult to require as prescriptiverequirements.Innovative building practices or emerging technologies can benefit from being listed in state and local building codes. How ever, states may havediff iculty prescriptively requiring new technologies or building practices for all homes that are not yet w idely available. For example, ground-sourceheat pumps can offer signif icant energy savings, but because of geological features or regulatory issues, they may not be appropriate in allcircumstances. The proposal above provides an incentive to consider installing a ground source heat pump as one of several compliance options underSection R407, but also offers many other comparable options or combinations of such options to achieve the same level of savings.

By incorporating several of these practices and technologies among the multiple options of Section R407, the proposal above essentially gives theseemerging technologies and practices a foothold, and allow s consumers and the market to determine the most feasible options for any given project. Asemerging technologies become more mainstream, Section R407 may also be a good source for additional improvements to the prescriptive baseline infuture code editions.

In sum, a few f inal observations may be helpful:

This Flex Points proposal is not an "above-code" program. Rather it is an additional eff iciency requirement that must be met by all residential buildingsw ith the choice among a number of compliance options. The IECC commercial provisions already contain a similar approach (see section C406).

This Flex Points proposal improves the 2015 IECC by 5% in three w ays:Homes can be built to the performance path and show an annual energy cost of no more than 95% of the standard reference design.Homes can be built to the ERI compliance path and meet an ERI score 5% below the current requirement.Homes can be built to any compliance path and code users can show that they have installed suff icient additional energy eff iciencymeasures to equal at least 5 Flex Points from the table column appropriate to the climate zone.

The Flex Points measures, in some cases, are not appropriate to require in the base code, either because of federal preemption issues or a lackof market penetration for new eff icient products, but are reasonable options for the builder to consider to achieve the additional 5% energyeff iciency targeted.The analysis is based on the Department of Energy Methodology for Evaluated Cost-Effectiveness of Residential Energy Code Changes and thepresent value calculation methodology, w hich w ill allow for easy updates to the table in the future. The analysis f irst uses a present valueanalysis over a 30-year useful life of the building to determine the present value of energy cost savings for each measure – specif ically, theanalysis calculates the energy cost savings on a present value basis for the estimated life of each measure up to 30 years. Then the estimateof energy cost savings is converted into points for each measure. Each point is equal to the present value of 1% energy savings over 20years; by using a 20 year benchmark for determining one point, the points allow more f lexibility among measures and provide some greaterrecognition to those measures w ith longer useful lives. While some measures have a longer life than 30 years, using a 30-year useful lifeensures that savings are capped at a commonly used 30-year metric for homes, such as a typical 30 year mortgage, w hich is conservativelylow for measures that last for the entire lifetime of the home.

Cost Impact: Will not increase the cost of constructionFor many builders, there w ill be no cost increase w hatsoever from compliance w ith this new requirement, since many of the Flex Points options arecommonly installed anyw ay -- such as improved HVAC equipment or ducts located indoors – and can satisfy all 5 f lex points (or more). For others w hoinstall a Flex Point option that otherw ise w ould not have been installed, there w ill be increased cost, but there are options available w ithin the proposalto achieve the 5 points cost-effectively.


RE180-16 : R407 (NEW)-CONNER12920

RE180-16R407 (New) [IRC N1107 (New)], R407.1 (New) [IRC N1107.1 (New)], Table R407.1 (New) [IRC TableN1107.1) (New)], R407.2 (New) [IRC N1107.2) (New)], R407.3 (New) [IRC N1107.3) (New)]Proponent : Craig Conner, representing self ([email protected]); Joseph Lstiburek, representingself ([email protected])


SECTION R407 (N1107) EQUIVALENT OPTIONS

R407.1 (N1107.1) Equivalent building option. Dwellings that meet both of the following criteria shall be deemed incompliance with this chapter.

1. The ratio of the air conditioning capacity to conditioned space is less than or equal to 1 ton per 1000 square feet.

2. The ratio of the heating system capacity to floor area of conditioned space is less than or equal to the the ratioindicated in Table R407.1 for the applicable climate zone.

TABLE R407.1 (N1107.1) RATIOS FOR HEATING EQUIVALENCY

Climate Zone 1 & 2 3, 4, & 5 6 7 & 8

Heating Sy stem Capacity in BTU/1000 square f eet

NA 20,000

25,000 30,000

NA = Not applicable

Reason: As Henry Gifford eloquently stated: Every designer is already paid to calculate the peak heating and cooling load for every building. This costis already paid for in 100% of the buildings built or renovated. In only a small fraction of cases does anyone actually do the math, but in 100% of thebuildings, someone does make an equipment size decision. Therefore, a code option like this w ill help get value that is already paid for, value w hich w illreduce cost by decreasing equipment size. At the same time everyone benefits from low er energy costs, improved comfort, better humidity control,low er noise levels, etc. Henry Gifford designs mechanical systems at the architecture f irm of Chris Benedict, R. A; a f irm that designs buildings thatare very energy eff icient, yet cost no more to build. A video by Chris Benedict and Henry Gifford presents the concept of "The Perfect Energy Code" in a commercial context. The video isat: https://w w w .youtube.com/w atch?v=Okn3Xgw SX5Q Its w orth w atching.

Cost Impact: Will not increase the cost of constructionThis is an option that gives considerable freedom to the designer/builder/ future ow ner. Options and f lexibility tend to low er construction costs.


https://www.youtube.com/watch?v=Okn3XgwSX5Q

RE181-16 : R407 (NEW)-CONNER13490

RE181-16R407 (New) [IRC N1107 (New)], R407.1 (New) [IRC N1107.1(New)], Chapter 6 (IRC Chapter 44)Proponent : Craig Conner, representing self ([email protected])

2015 International Energy Conservation CodeSECTION R407 (N1107) NATIONAL GREEN BUILDING STANDARD


R407.1 (N1107.1) Compliance satisfied. A building in compliance with at least the Silver level of the energy requirements inICC 700 in accordance with the Performance Path in Section 702 in ICC 700, the Prescriptive Path in Section 703 of ICC 700,or the HERS Index Target Path in Section 704 of ICC 700 shall be in compliance with all the requirements of this chapter.

Reference standards type: This reference standard is new to the ICC Code Books Add new standard(s) as follows: ICC 700-2016 (DRAFT Version) of the National Green Building Standard

Reason: The National Green Building Standard (NGBS, ICC 700) is part of the I-family and ANSI approved. The NGBS has multiple "green" partsincluding an Energy Chapter (chapter 7). At the low est level, Bronze, the Energy Chapter is roughly equal to the IECC, perhaps w ith a few morerequirements. At all higher levels the Energy Chapter is based on exceeding the energy eff iciency required by the IECC. At the Silver level the NGBSEnergy Chapter is about 7% better than the IECC in terms of reduced energy consumption. A home w hich has been approved by the NGBSverif iers (third party inspection) to go above the IECC should not be required to go through the code process to show it meets the IECC. The NGBS energy options include several approaches, all of w hich have minimum requirements in common. The prescriptive approach is similar to theprescriptive in the IECC. The performance approach is a calculation of energy savings based on an energy calculation specif ied in the IECC. The HERSIndex Target Path utilizes a calculation as defined by EPA for the Energy Star Program. The calculation computes a target score based on the specif ichome in question, then compares the proposed home to that target. Because the target is computed for each home based on its specif ic design andEnergy Star specif ications, it is a more accurate prediction of energy use than a generic HERS score. The calculation has the advantage of using onlyinput already provided for Energy Star calculation, provided by those w ho do the RESNET/HERS ratings/others, and w ill be accomplished by the samesoftw are. No new people or processes are required.

Cost Impact: Will not increase the cost of constructionThis is an option. Some w ho choose to go above the energy eff iciency in the IECC, to the Silver lever of ICC 700 or above, may increase the cost oftheir home. How ever, levels of energy eff iciency above the IECC could also be produced by good design, so it does not have to be a cost increase.

Analysis: A review of the standard proposed for inclusion in the code, ICC 700-2016 (DRAFT), w ith regard to the ICC criteria for referenced standards (Section 3.6 of CP#28), w ill be posted on the ICC w ebsite on or before April 1, 2016.


RE182-16 : R408 (NEW)-ZIMMER12124

RE182-16R407 (New) [IRC N1107 (New)], R407.1 (New) [IRC N1107.1 (New)]Proponent : Joseph Zimmer, Self, representing Joseph Zimmer, Architect ([email protected])


SECTION 407 (N1107) VERIFYING (RATING)

R407.1 (N1107.1) Verifying (rating). If requested by the code official, verification (rating) via performance tests andinspections by an approved agency in accordance with Section R104.4 shall be completed. Code official is permitted torequest a plan for verification that is inclusive of list and timing of performance tests and inspections prior to issuance ofbuilding permit. The order, timing and sequence of verification (rating) tests and inspections shall be when applicable systemsand components are accessible and exposed and shall be in coordination with inspections listed in Section R104.

Reason: Section is intended to be similar in purpose as Section C408 in the commercial provisions.If a code off icial requests, verif ication of component (building envelope, HVAC systems, Service Water heating systems and electrical pow er andlighting systems) could be verif ied as conforming w ith mandatory and other requirements.

Some of the tests and inspections w ould require specialized equipment and know ledge that the code off icial may not have.

If compliance is not verif ied during construction, performance levels and other issues may not meet the intent of the code.

Cost Impact: Will not increase the cost of constructionThe proposed section is only required w hen requested by the code official, w hen the code official determines a project w arrants verif ication ofcomponent and systems code compliance.If the code off icial does require verif ication, it is likely the approved agency performing the air leakage test required by Section R402.4.1.2 w ould alsoperform other tests and inspections. Some cost eff iciency is possible if added tests/inspections are performed at same time as the air leakage test.


RE183-16 : R502.1.1.2-MOZINGO13306

RE183-16R502.1.1.2 (IRC N1108.1.1.2), R503.1.2 (IRC N1109.1.2)Proponent : Shaunna Mozingo, Colorado Code Consulting - City of Cherry Hills Village, representing Colorado Chapter of ICC EnergyCode Development Committee ([email protected])


R502.1.1.2 (N1108.1.1.2) Heating and cooling systems. New heating, cooling and duct systems that are part of the additionshall comply with Section R403 Sections R403.1, R403.2, R403.3, R403.5 and R403.6.

Exception: Where ducts from an existing heating and cooling system are extended to an addition, duct systems withless than 40 linear feet (12.19 m) in unconditioned spaces shall not be required to be tested in accordance with SectionR403.3.3.

R503.1.2 (N1109.1.2) Heating and cooling systems. New heating, cooling and duct systems that are part of the alterationshall comply with Sections R403.1, R403.2, R403.3 and R403.6 Section R403.

Exception: Where ducts from an existing heating and cooling system are extended, duct systems with less than 40linear feet (12.19 m) in unconditioned spaces shall not be required to be tested in accordance with Section R403.3.3.

Reason: The charging statement for both of these sections let us know that these requirements only apply if you have "new heating, cooling and ductsystems that are part of the addition or alteration". It's not talking about the house, it's talking about installing new systems. Why w ould w e not w antthem to comply w ith all of the provisions of the code for systems in R403? If I put in a new system at any phase of construction I had better make sureit is sized for the building I'm putting it into. Don't tell me you can't do adequate sizing on an existing building. You can get it the absolute best that youcan but you at least have to put some thought into it. Maybe you don't require a Manual J or some type of load calculation if you are doing an addition or alteration and dealing w ith an existing system,although you should alw ays look to see if your mechanical equipment can handle the new load you're placing on it but it doesn't say that anyw here inthe code, but this isn't talking about existing systems. We alw ays have to do load calcs for new construction but never have to look at the systemagain to see if it is sized correctly for any future w ork that may be done to the home, even if w e add a 10,000 sq ft addition? Well if w e put in a newpiece of equipment, it should go through load calcs and sizing just like if it w ere being put in a new building.

These sections didn't just leave out load calcs/sizing for new equipment, it left out mechanical system piping insulation. Why? It left out new snow andice melt systems. Why? It left out pool and spa requirements. Again, w hy? If any of them are new , they need to meet all of the code requirements.

These sections should have read that heating and cooling and ducts systems that are part of the addition or alteration... and left out the w ord "new " ifthat w as their intent. But the w ay it is w orded, they are talking about new systems and they should have to comply.

Cost Impact: Will increase the cost of constructionThere w ould likely be a cost for having a load calculation done or for piping insulation to be done or w hatever requirement w ould have normally appliedhad the building been new but no longer applies because the building isn't new , even thought he equipment is.


RE184-16 : R503.1.1.1-FAY12769

RE184-16R503.1.1.1 (IRC N1109.1.1.1)Proponent : William Fay, representing Energy Efficient Codes Coalition; Charlie Haack, ICF International, representing Energy EfficientCodes Coalition; Maureen Guttman, Building Codes Assistance Project, representing Building Codes Assistance Project([email protected]); Harry Misuriello, American Council for an Energy-Efficient Economy (ACEEE), representing EnergyEfficient Codes Coalition; Jeffrey Harris, Alliance to Save Energy, representing Alliance to Save Energy; William Prindle, ICFInternational, representing Energy Efficient Codes Coalition


R503.1.1.1 (N1109.1.1.1) Replacement fenestration. Where some or all of an existing fenestration unit is replaced with anew fenestration product, including sash and glazing, the replacement fenestration unit shall meet the applicable requirementsfor U-factor and SHGC as provided in Table R402.1.2. Where more than one replacement fenestration unit is being installed, anarea-weighted average of the U-factor and/or SHGC of all replacement fenestration units shall be permitted to be used todemonstrate compliance.

Reason: This purpose of this code proposal is to clarify that the w eighted average performance of replacement w indow units can be used forcompliance purposes. Use of a w eighted average for compliance is consistent w ith the requirements both for fenestration in new homes and inresidential additions under this code and is also consistent w ith the requirements for replacement w indow s in the IECC – Commercial Provisions.

Cost Impact: Will not increase the cost of constructionSince the code requirements are not proposed to be changed, this proposal w ill not affect the cost of construction.


RE185-16 : R503.1.1-NORMAN11768

RE185-16R503.1.1 (IRC N1109.1.1)Proponent : Phillip Norman, Self, Phillip Norman Attic Access, representing self ([email protected])


R503.1.1 (N1109.1.1) Building envelope. Building envelope assemblies that are part of the alteration shall comply withSection R402.

Exception: The following alterations need not comply with the requirements for new construction provided the energyuse of the building is not increased:

1. Storm windows installed over existing fenestration.2. Existing ceiling, wall or floor cavitiesexposed during construction provided thatthese cavities are filled with insulation.2. Construction where the existing roof, wall or floor cavity is not

exposed.3. Roof recover.4. Roofs without insulation in the cavity and where the sheathing or

insulation is exposed during reroofing shall be insulated either above orbelow the sheathing.

5. Surface-applied window film installed on existing single panefenestration assemblies to reduce solar heat gain provided the codedoes not require the glazing or fenestration assembly to be replaced.

Reason: The exception is a gif t to blow and go installers of insulation, w ho shall instead be banished from publiclly endorsed business. In ceilings (atticf loors), more than half of potential energy savings are usually in the air sealing w hen not done dishonestly. Adding insulation then saves little energy,and perhaps fatally interferes w ith the needed sealing. Removal of the insulation in accomplishment of sealing might be avoidable at found conditions,and may be cost-prohibitive after insulation is added. In exterior w alls, in most climates, blow n-in insulation credited as air sealing w ill surely rot thehome. Floor cavities are usually accessible for sealing, often better than found in new homes, and must never be obstructed by new insulation, w ithoutsealing.

Cost Impact: Will increase the cost of constructionOf course, cost goes up w hen necessary w ork is not foregone. The concern is not for least cost to a house f lipper, but tor the operating cost to a newow ner and to society, w here new -home standards of eff iciency w ere possible, available, and not achieved. Those operating costs are usually ordersof magnitude greater than the foregone investment by an uncaring seller. Building code is w ritten for public good, not as enabling of small-change profitto builders and investors. Code mindful of safety and operating cost for subsequent home occupants w ill be of service to responsible builders andsellers, not then competing w ith counterfeit construction at slight mark-dow n. Think too of the buyer w ishing correction and f inding cost magnif ied bylost accessibility and by inf lation in labor and material costs.


RE186-16 : R503.1.4-NORMAN11776



R503.1.4 (N1109.1.4) Lighting. New lighting systems that are part of the alteration shall comply with Section 404.1.

Exception: Alterations that replace less than 50 percent of the luminaires in a space, provided that such alterations donot increase the installed interior lighting power.

Reason: The Exception is meaningless, w hile regulation for LED dow n lighting is under construction.

Cost Impact: Will not increase the cost of constructionWhere an existing home is upgraded, cost is an accepted trade for better usefulness and low ered operating costs. We do not see such cost asavoidable. Cost is only relative, as in one kind of light vs. another. High-eff icacy LED dow n lighting may cost much less than older and ineff icent, notdurable light forms. Savingsopportunity w ith LED dow nlighting is equal in new and existing homes. There is no need of, or potential for savings, in special rules for existing homes.


RE187-16 : APPENDIX RA-SURRENA12409

RE187-16Appendix RA (IRC Appendix T)Proponent : Donald Surrena ([email protected])


APPENDIX RA (APPENDIX T) RECOMMENDED PROCEDURE FOR WORST-CASE TESTING OF ATMOSPHERIC VENTING SYSTEMSUNDER R402.4 OR R405 CONDITIONS ≤ 5ACH50

Reason: This Appendix RA, "Recommended Procedure for Worst Case Testing of Atmospheric Venting Systems Under R402.4 or R405 Conditions, isnot appropriate as an appendix in the IECC. It is noted as "informative and is not part of the code." Appendices are typically included in code books tooffer optional or supplement criteria to the provisions in the main chapters of the code that are w ritten in mandatory language for adoption if chosen bythe jurisdiction. Appendices provide additional information for administration of the Department of Building Safety as w ell as standards not typicallyadministered by all building departments. Appendices have the same force and effect as the primary chapters of the code w hen explicitly adopted bythe jurisdiction. This Appendix RA is intended only as a recommended procedure to test venting and it is more appropriate in a training manual ortechnical guide for those parties that are involved in testing. This informational appendix is more appropriate in a standard and is not w ritten to be part ofa code that becomes law .

Cost Impact: Will not increase the cost of constructionThe code change proposal only serves to remove an optional appendix that appears to be misplaced in the IECC. As this Appendix is not a requirement,there is not a change in the cost of construction.


RE188-16 : APPENDIX RA-WILLIAMS13170

RE188-16Appendix RA, (IRC Appendix T)Proponent : Ted Williams, representing American Gas Association


APPENDIX RA (IRC APPENDIX T) RECOMMENDED PROCEDURE FOR WORST-CASE TESTING OF ATMOSPHERIC VENTING SYSTEMSUNDER R402.4 OR R405 CONDITIONS ≤ 5ACH50

All Sections and Tab les in the Appendix are deleted and are not shown for simplicity.

Reason: The procedures presented in the appendix are out of date w ith respect to other procedures documented in national consensus standards,including ANSI/BPI-1100-T-2014 "Home Energy Audit Standard," ANSI/BPI-1200-S-2015, "Standard Practice for Basic Analysis of Buildings,"BSR/ACCA 12 QH -2014, "Home Evaluation and Performance Improvement," and NFPA 54/ANSI Z223.1, "National Fuel Gas Code," (2015Edition). Efforts in 2014 and 2015 have led to the harmonization of these procedures across the standards, w hich are implemented by various types ofpractitioners, including code off icials. Most recently, Building America has published additional simplif ied test procedures for atmospherically ventedappliances that render the IECC Appendix RA methods, specif ically the depressurization limit requirements, obsolete. Since the appendix does notaddress energy eff iciency, it should be deleted, and further activity on professed needs for testing gas-f ired appliances should be proposed to theInternational Fuel Gas Code.

Cost Impact: Will not increase the cost of constructionBecause this appendix is non-mandatory, and requirements deleted w ould reduce most of commissioning and review of existing gas-f ired applianceinstallations, removal of the appendix w ould not increase costs of construction.


RE189-16Part 1:Appendix RB (IRC Appendix U) Part II:R202 (New), R801.4 (New), R801.4.1 (New), R801.4.2 (New), R801.4.3 (New), R801.4.4 (New),R801.4.5 (New), R801.4.6 (New), R801.4.7 (New)THIS IS A 2 PART CODE CHANGE. PART I WILL BE HEARD BY THE IECC-RESIDENTIAL CODE COMMITTEE. PART II WILL BE HEARD BY THE IRC BUILDINGCOMMITTEE. SEE THE TENTATIVE HEARING ORDERS FOR THESE COMMITTEES.

Proponent : Joseph Cain, SunEdison, representing Solar Energy Industries Association (SEIA) ([email protected])

Part 12015 International Energy Conservation CodeDelete without substitution:

APPENDIX RB (IRC: APPENDIX U) SOLAR-READY PROVISIONS—DETACHED ONE- AND TWO- FAMILY DWELLINGS, MULTIPLESINGLE-FAMILY DWELLINGS (TOWNHOUSES)

SECTION RB103 SOLAR-READY ZONE

RB103.1 General. New detached one- and two-family dwellings, and multiple single-family dwellings (townhouses) with notless than 600 square feet (55.74 m2) of roof area oriented between 110 degrees and 270 degrees of true north shall comply withSections RB103.2 through RB103.8.

Exceptions:1. New residential buildings with a permanently installed on-site renewable energy system.2. A building with a solar-ready zone that is shaded for more than 70 percent of daylight hours annually.

RB103.2 Construction document requirements for solar-ready zone. Construction documents shall indicate the solar-ready zone.

RB103.3 Solar-ready zone area. The total solar-ready zone area shall be not less than 300 square feet (27.87 m2)exclusive of mandatory access or set back areas as required by the International Fire Code. New multiple single-familydwellings (townhouses) three stories or less in height above grade plane and with a total floor area less than or equal to 2,000square feet (185.8 m2) per dwelling shall have a solar-ready zone area of not less than 150 square feet (13.94 m2). The solar-ready zone shall be composed of areas not less than 5 feet (1524 mm) in width and not less than 80 square feet (7.44 m2)exclusive of access or set back areas as required by the International Fire Code.

SECTION RB101 SCOPE

RB101.1 General. These provisions shall be applicable for new construction where solar-ready provisions are required.

SECTION RB102 GENERAL DEFINITION

SOLAR-READY ZONE. A section or sections of the roof or building overhang designated and reserved for the future installation of a solar photovoltaic orsolar thermal system.

RB103.4 Obstructions. Solar-ready zones shall be free from obstructions, including but not limited to vents, chimneys, androof-mounted equipment.

RB103.5 Roof load documentation. The structural design loads for roof dead load and roof live load shall be clearlyindicated on the construction documents.

RB103.6 Interconnection pathway. Construction documents shall indicate pathways for routing of conduit or plumbing fromthe solar-ready zone to the electrical service panel or service hot water system.

RB103.7 Electrical service reserved space. The main electrical service panel shall have a reserved space to allowinstallation of a dual pole circuit breaker for future solar electric installation and shall be labeled "For Future Solar Electric." Thereserved space shall be positioned at the opposite (load) end from the input feeder location or main circuit location.

RB103.8 Construction documentation certificate. A permanent certificate, indicating the solar-ready zone and otherrequirements of this section, shall be posted near the electrical distribution panel, water heater or other conspicuous locationby the builder or registered design professional.

Part II2015 International Residential CodeAdd new definition as follows:

SECTION 202 DEFINITIONS

ON-SITE RENEWABLE ENERGY. Energy generated by a renewable energy system located on the building site.


RE189-16 : APPENDIX RB-CAIN13531

SECTION 202 DEFINITIONS

RENEWABLE ENERGY. Energy derived from solar radiation, wind, waves, tides, landfill gas, biomass or the internal heat of the earth.


SOLAR-READY ZONE. A section or sections of the roof or building overhang designated and reserved for the future installationof a solar photovoltaic or solar thermal system.


R801.4 Solar ready zone. New construction of detached one- and two-family dwellings, and townhouses not more than threestories in height above grade plane in height, with not less than 600 square feet (55.74 m2) of roof area oriented between 110degrees and 270 degrees of true north shall comply with sections R801.4.1 through R801.4.7.

Exceptions:

1. New residential buildings with a permanently installed on-site renewable energy system.2. A building with a solar-ready zone that is shaded for more than 70 percent of daylight hours annually.

R801.4.1 Construction document requirements for solar ready zone. Construction documents shall indicate the solar-ready zone.

R801.4.2 Solar-ready zone area. The total solar-ready zone area shall be not less than 300 square feet (27.87 m2) exclusiveof mandatory access or set back areas. New multiple single-family dwellings (townhouses) three stories or less in height abovegrade plane and with a total floor area less than or equal to 2,000 square feet (185.8 m2) per dwelling shall have a solar-readyzone area of not less than 150 square feet (13.94 m2). The solar-ready zone shall be composed of areas not less than 5 feet(1.52 m) in width and not less than 80 square feet (7.44 m2) exclusive of required access or set back areas.

R801.4.3 Obstructions. Solar-ready zones shall be free from obstructions, including but not limited to vents, chimneys, androof-mounted equipment.

R801.4.4 Roof load documentation. The structural design loads for roof dead load and roof live load shall be clearlyindicated on the construction documents.

R801.4.5 Interconnection pathway. Construction documents shall indicate pathways for routing of conduit or plumbing fromthe solar-ready zone to the electrical service panel or service hot water system.

R801.4.6 Electrical service reserved space. The main electrical service panel shall have a reserved space to allowinstallation of a dual pole circuit breaker for future solar electric installation and shall be labeled "For Future Solar Electric." Thereserved space shall be positioned at the opposite (load) end from the input feeder location or main circuit location.

R801.4.7 Construction documentation certificate. A permanent certificate, indicating the solar-ready zone and otherrequirements of this section, shall be posted near the electrical distribution panel, water heater or other conspicuous locationby the builder or registered design professional.

Reason: Onsite solar energy systems are becoming more prevalent and cost effective. Many building departments have been mandated by localregulations to accelerate permits and inspections for solar installations. Having important information and documentation available to the buildingdepartment, solar contractor and homeow ner w ill assist in supporting the accelerated w orking environment many municipalities have mandated. It alsoprovides uniform guidance for those jurisdictions w here solar ready ordinances are under consideration.This proposal is intended to identify the areas of a residential building roof, called the solar ready zone, for potential future installation of renew ableenergy systems. This proposal requires documenting necessary solar ready zone information on the plans, some of w hich may already be required inpermit construction requirements. This proposal also requires the builder to post specif ic information about the home for use by the homeow ner(s).

The proposed language follow s language currently approved in Appendix U of the 2015 IRC. This proposal does not require the installation of conduit,pre w iring, or pre-plumbing. It does not require any specif ic physical orientation of the residential building. It does not require any increased loadcapacities for residential roofing systems. It does not require the redesign of plans.

This proposal moves Appendix U into the main body of the IRC, thereby allow ing the builder to allow a home ow ner to install a rooftop PV or thermalsolar system at the time of construction or at a later time. Many jurisdictions are already requiring these provisions. Having a home ready for solar w illalso be a positive selling feature for the home. Chapter 8 is the most logical location for requirements for solar ready zones, as this chapter providesdesign guidance for roof construction.

Cost Impact: Will increase the cost of constructionAlthough this proposal w ill likely increase the cost of construction, it can be minimal if proper design guidance is follow ed. For example, minor increasein cost could be associated w ith alternative ventilation paths for plumbing f ixtures and/or appliances in order to leave clear roof space for the solarready zone. Depending on design features, minor increase in cost could be associated w ith providing an interconnection pathw ay for routing of conduitand/or plumbing from the solar-ready zone to the electrical service panel or service hot w ater system. Many jurisdictions are already adopting theseprovisions.


RE190-16 : R303.1.5 (NEW)-WILLIAMS12252

RE190-16R303.1.5 (New) [IRC N1101.10.5 (New)]Proponent : Jeremiah Williams ([email protected])


R303.1.5 (N1101.10.5) Equipment rating and information. Where requested by the code official, following information forthe HVAC and water heating equipment shall be provided:

1. Rated efficiency.2. Date of manufacture.3. For equipment for which the U.S. Department of Energy regulations CFR Title 10, Part 430 provide for different

efficiencies as a function of a geographic region or intended installation location, the geographic region or statewhere the equipment will be installed.

Reference standards type: This is an update to reference standard(s) already in the ICC Code Books Add new standard(s) as follows: U.S. Department of Energy (DOE) 10 CFR, Part 430-1998 Energy Conservation Program for Consumer Products: TestProcedures and Certification and Enforcement Requirement for Plumbing Products; and Certification and EnforcementRequirements for Residential Appliances; Final RuleReason: Because HVAC equipment plays a crucial role in determining the overall eff iciency of a residence, it is important that installed HVAC equipmenthave the expected eff iciencies. This is especially important because of the addition of the Energy Rating Index (ERI) path in the 2015 IECC, and the needfor code off icials to know the installed eff iciencies in order to verify compliance under that path. Further, because new Federal requirements for someHVAC equipment varies by region, code off icials have a greater need for ready access to the equipment ratings installed in homes. The proposedchange assures that information about the equipment is readily available.

Energy Savings: The proposal is not expected to produce energy cost savings.


Cost Impact: Will not increase the cost of constructionThis change w ill not increase the cost of construction because it merely requires that the builder make information that is expected to already be in hisor her possession available to the code off icial.

Analysis: The standard proposed for inclusion in this code, Uunited States Department of Energy (DOE) 10 CFR, Part 430-1998 is referenced in theInternational Energy Conservation Code-Commerical Provisions.



RE191-16R403.5.3 (New) [IRC N1103.5.3 (New)], R403.5.3.1 (New) [IRC N1103.5.3.1 (New)], R403.5.3.2 (New) [IRC N1103.5.3.2 (New)], Table R403.5.3.2 (New) [IRC Table N1103.5.3.2 (New)], R403.5.3.3 (New) [IRC N1103.5.3.3 (New)], Table R405.5.2(1) [IRC Table N1103.5.2(1)]Proponent : Karen Hobbs, Natural Resources Defense Council, representing Natural Resources Defense Council ([email protected])


R403.5.3 (N1105.5.3) Hot Water Proximity to Point of Use (Prescriptive) Hot water distribution systems for detached one-and two- family dwellings and townhouses shall be designed in accordance with Sections R403.5.1 through R403.5.3.

R403.5.3.1 (N1103.5.3.1) Scope The distance limitation in Section R403.5.3.2 shall apply to the following plumbing fixturessupplied with hot water in detached one- and two-family dwellings and townhouses: 1. lavatories. 2. kitchen sinks. 3. showers. 4. tub-shower combinations.

Exception: Plumbing fixtures connected to a hot water recirculation system.

R403.5.3.2 (N1103.5.3.2) Maximum distance to certain plumbing fixtures. For hot water distribution systems servingindividual dwelling units, the maximum distance in plan view between the location of a water heater and a plumbing fixturereceiving hot water from it shall be no more than the length shown in Table R403.5.3.2. For purposes of this determination, thelocation of a water heater shall be translated vertically to each floor on which a fixture served by such water heater is located.

TABLE R403.5.3.2 (N1103.5.3.2)MAXIMUM DISTANCE BETWEEN A WATER HEATER AND CERTAIN PLUMBING FIXTURES

Dwelling Unit

Floor Area (ft2)

Maximum Distance in Plan View (ft)

Two- or More Story Structures One-Story Structures

≤1000 20 f t. 30 f t.

>1000 to ≤1600 30 f t. 40 f t.

>1600 to ≤2200 40 f t. 50 f t.

>2200 to ≤2800 45 f t. 55 f t.

>2800 50 f t. 65 f t.

R403.5.3.3 (N1103.5.3.3) Points of measurement. The distance in plan view shall be determined by the length of a straightline between the center point of the water heater and the hot water outlet of a plumbing fixture indicated in Section R403.5.3.1.

Revise as follows:


Portions of Tab le not shown remain unchanged


Serv ice water heating d, e, f , g ,i, jAs proposed

Use: same as proposed designUse: gal/day = 30 + (10 × Nbr )


Use: gal/day = 30 +((4 × DFFp ⁄MDr +6) ×

Nbr )











i. DFFp = Distance in plan view from the hot water heater to the furthest fixture specified in Section R403.5.3.1. MDr = MaximumDistance specified in Table R403.5.3.2.j. Service water heating use shall be the same as the standard reference design for a proposed design with any of the following:

1. a hot water recirculation system.2. a building type not specified in Section R403.5.3.1.3. where DFFp ⁄MDr is less than 1.0 and greater than 0.75.

Reason: Purged Hot Water is Wasted Energy

Cold or tepid w ater in the initial draw from a hot w ater outlet is often unsuitable for its intended purpose and is frequently purged, resulting in a w aste ofw ater, energy, and time for residents.

A 2009 paper by Robert Hendron of the National Renew able Energy Laboratory and others quantif ied the w aste of hot w ater in initial draw s w aiting forw ater to reach 105°F. Modeling the plumbing typical in a 3-bedroom, 2-bath single-story home w ith a hot w ater simulation tool found that an estimated12% of all hot w ater used on an annual basis is w asted. When view ed by f ixture, the results are as follow s:

Show ers -- over 10% w astageKitchen sinks -- 18% w astage.Lavatories -- over 30% w astage.

Purging at these f ixtures is responsible for 95% of the estimated total of nearly 3,000 gallons of hot w ater w astage annually. Of course, many newhomes are built w ith more hot w ater outlets than this model's base case. Both energy and w ater can be saved by reducing the volume of w ater that issubject to cool-dow n in the hot w ater distribution piping, by careful attention to the proximity of the hot w ater heater and the points of hot w ater use.

A Proposal for Reducing Hot Water PurgingThis proposal seeks to reduce entrained hot w ater volume in one- and tw o-family homes and tow nhouses by --

Adding a prescriptive requirement to Section 403 that sets accomodative but clear limits on the distance betw een a hot w ater heater and thefurthest bathroom or kitchen f ixture it serves; andOffering credit in the performance alternative in Section 405 for proposed designs that save energy by signif icantly increasing the proximity ofhot w ater heaters and f ixture outlets compared to the basic prescriptive level established in Section 403.

Providing greater proximity betw een the hot w ater heater and the f ixtures using hot w ater w ill reduce the need for purging throughout the life of thebuilding. This proposal is similar in intent and effect to Section 607.2 of the International Plumbing Code, w hich sets a maximum developed length of 50feet for hot w ater supply piping betw een a heat source and any hot w ater f ixture. (In most jurisdictions, how ever, the IPC applies to commercial andlarge multifamily residential buildings, rather than one-and tw o-family homes.) While not a limitation on pipe length or internal volume per se, this proposaloffers a w orkable proxy for internal pipe volume and has the great advantage of requiring no special draw ings nor any measurements or calculations atthe job site. Rather, its simple provisions can be easily applied during project design and confirmed at plan check, and its graduated distance limitsbased on the square footage of the home meet the need for a f lexible approach that respects the diversity of types and sizes of homes covered by thecode.

An ineff icient hot w ater distribution system is likely to remain in place for the life of a building, leaving ow ners w ithout practical access to energy-savingoptions that w ould have only been feasible at the time of construction. This proposal w ill direct the attention of designers and code off icials to theproximity betw een w ater heaters and those f ixtures that are responsible for the great majority of hot w ater w aste.

The Prescriptive RequirementIn this proposal, proximity betw een a dw elling's hot w ater heater and the f ixture outlets it serves is measured by the straight-line distance in plan viewbetw een the w ater heater and the f ixture outlet. For multi-story homes, the proposal specif ies that the location of the hot w ater heater "shall betranslated vertically to each f loor on w hich a f ixture served by such w ater heater is located." In other w ords, the maximum straight-line distance isapplied separately on each f loor, forming an arc from a point on each f loor that is directly above the location of the hot w ater heater in the basement.

Plans for most tw o-story production homes should comply w ith the prescriptive provision w ith little or no adjustment. Most home designs w here theprincipal length-to-w idth ratio of the building footprint is 2 to 1 or less should face few compliance issues. The concept may be more challenging forsingle-story structures, and for that reason an additional distance allow ance is provided for single-story homes. Plans for homes w ith long and narrowconfiguration may require adjustment, largely to avoid positioning the hot w ater heater and its furthest f ixture outlet at diagonally opposite corners of thebuilding. Avoiding such inherently ineff icient designs is the primary intent of the prescriptive proposal, and architects and builders can easily identifyany compliance issues at an early stage.

The illustrations below (Figures 1-4) offer a demonstration of the simplicity of applying the proximity limits in practice.

Figure 1. This is a very basic schematic of a small single-story home of 1,000 square feet. As per the values in the proposal's table (TableR403.5.X.2), the straight-line distance allow ed betw een the w ater heater and the outlet of a hot w ater f ixture is 30 feet. In this example, the w aterheater is positioned in the corner of the house plan. If all kitchen and bathroom hot w ater f ixtures are w ithin the 30-foot arc, the plan is compliant. How ever, if the outlet of such a hot w ater f ixture is located outside the 30-foot arc, the plan does not comply.


Figure 2. A second illustration of the same sized small home show s the effect of moving the hot w ater heater to a more central location. In Figure 2,the position of the hot w ater heater is at a more central point along an exterior w all. This entire home falls w ithin the 30-foot arc, and the plan w ould becompliant for all possible locations of hot w ater outlets w ithin this home.


Figure 3. This third illustration show s the plan for a somew hat larger one-story home, w ith 2,200 square feet. In Figure 3, as per the values inproposed Table R403.5.X.2, the straight-line distance allow ed betw een the w ater heater and the outlet of a hot w ater f ixture listed in the f irst paragraphof the proposal is 50 feet. Here, all hot w ater outlets fall w ithin the 50-foot arc, so the plan complies. Note, how ever, that if the master bath had beenplaced in the location of the sitting room, it is possible that one or more hot w ater outlets w ould have fallen outside the 50-foot arc, and such a planw ould not comply. But some adjustment of f ixture locations w ithin the master bath by the designer w ould likely have brought the plan into compliance.


Figure 4, Sheets 1, 2, and 3. A fourth illustration (on 3 sheets) demonstrates the application of the proposal to multi-story homes, in this case, a homeof 2,600 square feet and a maximum straight-line distance allow ance of 45 feet. In this example, the hot w ater heater is located in the basement, asshow n in Figure 4, Sheet 3. Section R403.5.3.2 of the proposal specif ies that the location of the hot w ater heater "shall be translated vertically to eachfloor on w hich a f ixture served by such w ater heater is located." In other w ords, the maximum straight-line distance is applied separately on eachfloor, measured from a point on each f loor that is directly above the location of the hot w ater heater in the basement. In Figure 4, Sheets 2 and 1, onecan see that the point of measurement on both the f irst and second f loors is the same position in the plane of each f loor as the position of the hot w aterheater in the plane of the basement. In this example, this relatively compact house design easily complies w ith the 45-foot maximum distance for a multi-story home of this square footage.


The Performance CreditThe performance credit w ill encourage designs that achieve closer proximity betw een the w ater heater and f ixture outlets than the maximum limits ofthe prescriptive proposal. A credit is provided in the form of a reduction in the deemed value for service w ater heating volume, and is show n in arevision to the row in existing Table R405.5.2 currently specifying how service w ater heating volume is to be calculated. The proposal maintains thesame general formula, but makes dow nw ard adjustments in the additional volume specif ied for each bedroom.

Several low -cost strategies are available to designers and builders to reduce the distance betw een the hot w ater heater and f ixture outlets and obtainthis performance path credit, including f ixture repositioning and w ater heater repositioning. This can often be accomplished by repositioning theproposed w ater heater location from an exterior garage w all to an interior garage w all; moving a basement w ater heater from a corner tow ard a morecentral location; or rearranging f ixture locations in a bathroom to move hot w ater outlets closer to the w ater heater. Installation of a point-of-use hotw ater heater is also an option. (Note how ever, that installation of a hot w ater recirculation loop, w hile permitted, is not aw arded performance credit inthis proposal.)

A simple table show s how the performance credit w ill apply to common home configurations.

Illustrative Impact of Proximity:Reductions in Hot Water Volume for the Proposed Design

Numberof BedRooms

StandardRef erence

Design

Proposed Design @ 75% ofprescriptiv e maximum distance in

plan v iew

Proposed Design @ 50% ofprescriptiv e maximum distance in

plan v iew

Hot Water

Volume(g/day )

Hot WaterVolume (g/day )

Reduction fromstandard reference

design (%)

Hot WaterVolume(g/day )

Reduction fromstandard reference

design (%)

2 50 48 4 46 8

3 60 57 5 54 10

4 70 66 5.7 62 11.4


RE191-16 : R403.5.X (NEW)-HOBBS11734

5 80 75 6.2 70 12.5

As can be seen, for larger homes (as indicated by the number of bedrooms), the benefits of closer proximity are proportionately larger.

Credit for improved hot w ater distribution eff iciency is now available to designers and builders follow ing the energy rating index (ERI) approach underSection R406. This proposal w ill allow for comparable credits to be earned by builders follow ing the performance path specif ied by Section R405. Without this proposal, improvements in hot w ater distribution eff iciency w ill go unrecognized and unrew arded for performance path builders.

Bibliography: "Potential for Energy Savings through Residential Hot Water Distribution System Improvements," Proceedings of the 3rd InternationalConference on Energy Sustainability, San Francisco, CA, Herndon, Robert, et al, July 2009.Single Family Water Heating Distribution System Improvements, Codes and Standards Enhancement Initiative (CASE), California Utilities Statew ide Codesand Standards Team, draft May 2011.

Single Family Water Heating Distribution System Improvements, Codes and Standards Enhancement Initiative (CASE), California Utilities Statew ide Codesand Standards Team, f inal September 2011.

Cost Impact: Will not increase the cost of constructionThis proposal is a design requirement that can be met w ithout increasing the cost of construction. Plans that may be initially out of conformance w iththe prescriptive proposal can most commonly be adjusted w ith strategies that need not carry a cost penalty, such as repositioning the proposed hotw ater heater location from an exterior garage w all to an interior garage w all, or by rearranging f ixture locations in a bathroom to move hot w ater outletscloser to the w ater heater. Such changes typically result in shorter lengths of both cold and hot w ater piping, thereby rediucing costs. The CASEreport referenced in the bibliography evaluated the cost-effectiveness of radial distance limits that w ere signif icantly more stringent than theprescriptive levels proposed here, and found them to be cost-effective in all cases. (See f inal report, pp. 20-21.) The report's estimate even assumedan initial cost of $390 for additional lengths of natural gas piping and w ater heater vent piping, even though repositioning a w ater heater from an outergarage w all to an inner garage w all need not increase gas service line length. Cost savings averaging $73 from reduced length of PEX hot w ater pipingw ere estimated. Natural gas savings of 24 therms per year more than offset these costs on a life-cycle basis. What's more, no savings w erecalculated or credited for reduced w ater and sew er charges over the life of the building, w hich w ould further confirm the cost-effectiveness of thismeasure.Energy- and w ater-saving designs encouraged by this proposal w ill enhance housing affordability by reducing unnecesary pipe matertial andinstallation costs and through reduced energy, w ater, and sew er bills of building ow ners and occupants over the life of the building.
