Dear Board Members and Staff,

On behalf of the NRDC (Natural Resources Defense Council) and our over 9,500 paying members in Virginia, we submit the following comments on the proposal to update the energy provisions of Virginia’s Uniform Statewide Building Code (USBC).

This update is an important and long-lasting opportunity for the Board to protect the economic well-being of Virginians for generations to come.  Just as impactful, buildings are responsible for about 40 percent of all carbon emissions in the US, and the buildings constructed today will be in use for 50 to 100 years, or more. In addition to long-lasting climate benefits, constructing efficient buildings from the start will yield energy and cost savings over the entire lifetime of the building, while ensuring greater levels of comfort and safety for inhabitants.

Virginia has recognized the need to act to avoid the most costly impacts of climate change, recently passing the Virginia Clean Economy Act and joining the Regional Greenhouse Gas Initiative to reduce carbon pollution from the power sector. A strong, robust, continually-improving building energy code is a crucial policy tool that is fully consistent with the Commonwealth’s carbon reduction goals. In fact, it will be impossible to achieve meaningful climate goals without addressing the energy consumption of buildings. Improving building energy efficiency is one of the best and most cost-effective tools we have to reduce the effects of climate change, while keeping people more comfortable and lowering energy bills.

NRDC fully supports Virginia’s efforts to update the energy provisions of the USBC. We encourage clean adoption of the 2018 International Energy Conservation Code (IECC), with strengthening amendments as described below.

Adopt the 2018 IECC

We urge Virginia to adopt, at a minimum, the 2018 IECC without any amendments that would weaken the efficiency of the code. Currently Virginia follows the 2015 IECC, but with weakening amendments. Given the scope and magnitude of the climate crisis, it is important for new buildings to be built as efficiently as possible, and as soon as possible. A number of other states, including neighboring Maryland, have adopted energy codes that are at least as efficient as the 2018 IECC, and with no weakening amendments.

Compared to the current USBC, the 2018 IECC includes more stringent requirements for building envelope improvements, including better wall insulation, ceiling insulation, and air infiltration requirements. These measures will cost about $600 more to install at the time of construction. However, according to analysis by the Responsible Energy Codes Alliance, improved insulation requirements will save upwards of $100 each year – savings that continue through every year of the life of the building.

People who purchase new construction homes tend to have higher incomes, with nearly half reporting a household income of more than $100,000. However, long-term savings measures installed at the time of construction are important for lower income residents, as well. The second, third, or fourth owners or occupants of any given home may be households with lower incomes. The benefits of measures like insulation will last for the lifetime of the home, and will benefit subsequent homeowners or renters. 

Likewise, improved efficiency is especially important in multifamily buildings, which tend to be rented rather than owned. Renters have very little control over the building envelope and equipment, and can suffer the consequence of high energy bills with no way to improve the building. Constructing efficiently from the start will mean lower bills and better health and comfort for years to come.

Additional Improvements Mean More Benefits

Adopting the 2018 IECC without weakening amendments should be the absolute minimum.

There are a number of additional strengthening proposals that should be considered and adopted.

Require electric readiness

A key component of the fight against costly climate change is reducing the use of fossil fuels, including fossil fuels used on site in a building for water heating, space heating, clothes drying, and cooking. Preparing a building for future electrification of some of these end uses is straightforward and inexpensive at the time of construction: it simply requires the appropriate electrical outlet and spacing for future electric appliances. Doing so protects homeowners from future costs, should natural gas become less affordable or even unavailable over the life of the building. In addition, there are substantial indoor air quality benefits from choosing electric equipment over fossil fuel combustion equipment, which could be very important for people with certain health conditions.

As the electric grid becomes cleaner, and high-efficiency electric heat pump technology increasingly offers utility bill and pollution reduction benefits over gas, more customers may want to transition from natural gas to electric space and water heating. Federal, state, and local environmental and public health policies may also encourage, or even require the transition in some areas. Electric-ready requirements will protect customers from high retrofit costs. Proposal RE147-19 was recently adopted into the 2021 IECC, and language in that proposal should be considered for adoption in Virginia.

Require electric vehicle readiness

Similar to making a building ready for future electrification of end uses, homes, multifamily buildings, and commercial buildings should be required to meet electric vehicle (EV) readiness requirements. This does not mean installing a full EV charging system, but simply ensuring that the proper wiring, circuitry, and electrical panel space is available for the installation of a future EV charger. The cost savings of installing EV capability at the time of construction is immense: a 2018 study by the California Air Resources Board found a cost savings of up to $8,000 by installing EV charging infrastructure in commercial/multifamily buildings, as compared to the cost of retrofitting. Proposals CE217-19 Part 1 and CE217-19 Part 2 were both adopted as part of the 2021 IECC, and should be considered as an appropriate model for electric vehicle readiness.

Continual Improvement

Virginia’s building code has lagged behind the model IECC codes for far too long. Given the magnitude of the power plant carbon reductions required under the Virginia Clean Economy Act, Virginia must prioritize the energy efficiency of its new construction. Adopting a clean 2018 code is a start, but progress must continue. We request that the Board of Housing and Community Development adopt a policy committing Virginia to adopt the most recent IECC, without weakening amendments, each time it is updated. Failure to do so will mean higher bills for residents and businesses, more wasted energy, and more climate pollution for decades to come.

Better building codes are a common-sense way to address costly climate change while saving money and energy in the immediate term.

Updating to the 2018 IECC, without weakening amendments, is a great start – but it doesn’t go far enough. Committing to more energy efficiency both now and in the future will mean a healthier, cleaner Virginia for all.

Thank you,

Walton C. Shepherd

Virginia Policy Director & Senior Attorney, NRDC

2105 M Street, Richmond, VA 23223