Sir or Madam,

Nationally, all non-manufacturing buildings account for approximately one third of CO2 emissions and 70% of electrical consumption. Obviously, there is a great need for building codes that ensure energy efficiency and these codes must be based upon tested standards. The 2012 and 2015 International Energy Conservation Code (IECC) provisions provide a logical methodology for CO2 emissions reduction and I support their adoption.

If full adoption of the 2012 and 2015 IECC provisions is not possible, please consider adopting the provisions recently submitted by Andrew Grigsby of the Local Energy Alliance Program and others. They are as follows: 

-Envelope tightness: Eliminate the visual inspection option and lower the hourly air change rate of five to three.

-Duct tightness: Eliminate the visual inspection option and lower the current leakage limits from eight CFM to     four CFM.    

 -Insulation R value: In walls, increase it from a minimum of 15 to 20 and in attics increase it from 38 to 49.

The option for visual inspection in lieu of mechanical testing is laughable. It is analogous to asking a floor installer if the installed floor is level and him/her basing his/her assessment on looking at the floor instead of using a mechanical level.

Frequently, home builders complain that adhering to strict energy saving standards is too costly, however, there are good arguments that, strategically speaking, the initial costs are, at minimum, equalized over time. A University of North Carolina study found that the mortgage default rate is lower for energy efficient homes. Additionally, the National Association of Home Builders found that nine of ten new home buyers are willing to pay two percent more for energy efficient homes and that the 2012 IECC code implementation would provide a five percent return on the initial investment. 

Gary Medlin, Chesapeake Bay Group Sierra Club